Kazakhstan moves to make casino and bookmaker executives personally liable for AML breaches

Kazakhstan’s Ministry of Tourism and Sports has published a draft order that would shift anti-money laundering liability from companies to named individuals. For PSPs and acquiring teams working with casinos, bookmakers, and lotteries in the market, that is the part worth watching: compliance failures would no longer sit neatly at the entity level.

1. The draft covers executives of casinos, betting companies, and lottery operators, as well as employees responsible for financial monitoring. The public discussion period runs until 13 November 2026.
2. Under the proposal, liability would apply not only for failing to meet AML requirements, but also for breaches tied to countering terrorist financing and the proliferation of weapons of mass destruction. The ministry says this includes both direct involvement in illicit transactions and failures in mandatory financial control procedures.
3. Those procedures include customer due diligence, monitoring suspicious transactions, submitting information to the Financial Monitoring Agency, and in some cases refusing to process a transaction or ending a customer relationship. The publication does not specify the size of the sanctions.
4. The ministry says the change is meant to align Kazakhstan’s rules with FATF Recommendation 35, which calls for effective and proportionate sanctions, including for senior management where their actions or inaction led to violations. It also says the draft is intended to address shortcomings identified in the country’s external AML/CFT assessment.
5. The backdrop matters. In December 2025, the Financial Monitoring Agency said it had uncovered an illegal transfer scheme linked to online casinos worth more than 600 billion tenge (around $1,25 billion), involving more than 20 payment organizations and some bank employees. The money reportedly moved through “gray” POS terminals and fake contracts with bookmakers. In October 2026, another illegal iGaming network with turnover of 188 billion tenge (around $400 billion) was shut down, also with involvement from parts of the local banking sector.

For payment providers, the practical signal is simple: Kazakhstan is pushing accountability deeper into the operational chain. When regulators start naming people, not just entities, banks and PSPs usually get a lot less relaxed about who signs off on monitoring, escalation, and transaction screening.