2019-08-14 | 134285Added
This Regulation, last amended on October 1, 2026, sets minimum internal control requirements for commercial banks, microfinance companies, OJSC "Financial Company of Credit Unions", and housing savings credit companies in the Kyrgyz Republic regarding anti-money laundering and countering the financing of terrorism (AML/CFT). It mandates the implementation of an internal control program, including annual risk assessments, comprehensive client due diligence, and reporting suspicious operations to the financial intelligence unit. Notably, the regulation introduces new obligations for banks to employ automated tools, including blockchain analytics, for monitoring virtual asset operations and to identify high-risk virtual asset transactions based on specific criteria such as untraceable wallets or anonymity-enhancing services. Banks must also establish internal procedures for managing virtual asset-related risks and assess their resources before engaging with clients or counterparties involved in virtual assets.
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Date of creation: 2026-10-06
Appendix 1
to the Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 14, 2019 No. 2019-P-12/42-1-(NPA)
REGULATION
On Minimum Requirements for Organizing Internal Control in Commercial Banks to Counter the Financing of Criminal Activity and Legalization (Laundering) of Criminal Proceeds
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated September 15, 2021 No. 2021-P-12/51-1, December 14, 2022 No. 2022-P-12/78-10, December 28, 2022 No. 2022-P-12/83-7, December 27, 2023 No. 2023-P-12/82-7, January 17, 2024 No. 2024-P-12/1-3, December 19, 2025 No. 2025-P-12/68-2-(NPA), August 28, 2026 No. 2026-P-14/44-1-(NPA)), October 01, 2026 No. 2026-P-12/48-2-(NPA)
Chapter 1. General Provisions
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 2. Concepts and Definitions
Beneficial owner - a natural person (natural persons) who ultimately (through a chain of ownership and control) directly or indirectly (through third parties) owns or controls the client, or a natural person on whose behalf or in whose interest an operation (transaction) is carried out.
Close relatives (parents, adoptive parents, adopted children, full-blood and half-blood brothers and sisters, grandfather, grandmother, grandchildren, for whom a public official incurs financial expenses, in terms of covering living expenses, education, healthcare, and other necessary expenses).
Verification - the procedure for checking the identification data of the client and (or) the beneficial owner.
High-risk countries - states and territories (entities) that do not apply or apply insufficiently international standards for combating money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, as well as offshore zones.
Identification of operations subject to control and reporting - a stage of organizing a bank's internal control for CFT/AML purposes, which includes determining operations subject to control and reporting to the financial intelligence unit in accordance with the requirements of regulatory legal acts of the Kyrgyz Republic.
CFT/AML Officer - a bank employee (at the level of the head of the compliance control service), appointed for the purpose of organizing internal control for CFT/AML, having access to all information related to the identification, verification, detection, recording, and transmission of data to the financial intelligence unit.
The CFT/AML Officer, for the purpose of promptly performing their functions, has the right to delegate powers to employees under their subordination. However, this circumstance does not relieve the officer of responsibility for improper performance of their functions.
Identification - the procedure for establishing identification data about the client and (or) the beneficial owner.
Source of funds - information about the origin of specific funds or assets that are the subject of business relations between the client and the bank. The information obtained must be substantive, indicating the source and/or grounds for obtaining or acquiring these funds or assets.
Source of other property - information about the origin of the aggregate property of a public official (the source of formation of all assets belonging to the client). The information obtained reflects data on the client's status and how the client acquired it.
Client - a natural or legal person (organization), foreign trust, or legal entity accepted for service or being serviced by the bank, or with whom banks establish or have established business relations.
Financial intelligence unit - the authorized state body of the Kyrgyz Republic in the field of countering the financing of criminal activity and the legalization (laundering) of criminal proceeds.
Suspicious operation (transaction) - an operation (transaction) falling under the following signs:
a) if there is suspicion or sufficient grounds to suspect that the funds are proceeds from crime, including predicate offenses, or are related to the legalization (laundering) of criminal proceeds;
b) if there is suspicion or sufficient grounds to suspect that the funds are related to the financing of:
A suspicious operation (transaction) is determined by the CFT/AML Officer within the framework of legislation in the field of CFT/AML for operations carried out with funds or other property of the client and the beneficial owner.
Internal Control Program - internal measures, procedures, and control systems applied by the bank to comply with the legislation of the Kyrgyz Republic in the field of CFT/AML.
Public officials - one of the following natural persons:
a) foreign public official - a person performing or having performed significant state or political functions (public functions) in a foreign state (heads of states or governments, senior officials in government, courts, armed forces, state bodies, enterprises or institutions, prominent political figures, including prominent figures of political parties);
b) national public official - a person holding or having held a political and special state position in the Kyrgyz Republic, provided for in the Register of State and Municipal Positions, approved by the President of the Kyrgyz Republic, as well as senior management of state corporations, prominent political figures, including prominent figures of political parties;
c) public official of an international organization - a senior official of an international organization who has been entrusted with or has performed important functions by an international organization (heads, deputy heads, and board members of an international organization or persons holding equivalent positions in an international organization).
Risk-based approach - the application of enhanced measures in the presence of a high level of risk or simplified measures in the presence of a low level of risk in accordance with established risk management procedures (identification, assessment, monitoring, control, risk mitigation).
Sanction Lists - the Consolidated Sanction List of the Kyrgyz Republic and the Consolidated Sanction List of the UN Security Council.
The procedure for forming and publishing sanction lists is provided for in the Regulation "On Lists of Natural Persons and Legal Entities, Groups and Organizations for which there is information about their participation in criminal activity and legalization (laundering) of criminal proceeds", approved by Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated November 14, 2025 No. 739.
The concept of "extremist activity" corresponds to the norms of the conceptual apparatus of the Law of the Kyrgyz Republic "On Countering Extremist Activity".
"Islamic bank", "bank with an "Islamic window", "Islamic banking and finance principles", "Sharia standards", "Sharia Council" - these terms correspond to the norms of the conceptual apparatus of the Law of the Kyrgyz Republic "On Banks and Banking Activity" and regulatory legal acts of the National Bank.
All other concepts used in this area must not contradict the main concepts set forth in this chapter.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 3. Bank Activity in the Field of CFT/AML
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The Bank's Management Board must take comprehensive measures to prevent the bank's involvement in operations showing signs of suspicious operations.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA)) \
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 28, 2026 No. 2026-P-14/44-1-(NPA))
Chapter 5. Assessment of the Effectiveness of Internal Control for Countering the Financing of Criminal Activity and Money Laundering (hereinafter - CFT/AML) by the Bank's Internal Audit Service
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
assessment of the effectiveness of the organization of the internal control system, including policies, procedures, and the organization of the bank's activities for CFT/AML;
assessment of the methodology for determining risk levels adopted by the bank;
assessment of the measures applied by the bank to assess and manage the bank's exposure to CFT/AML risks;
selective testing of the activities of the CFT/AML Officer, including the software used, also for compliance with the bank's policies and procedures;
assessment of measures applied by the bank's management, Management Board, and Board of Directors to eliminate violations identified during previous inspections by the bank's internal audit service, external audit, the National Bank, or the financial intelligence unit;
review-assessment of internal control, including assessment of the effectiveness of the software used for identifying and generating reports on operations (transactions) subject to control and reporting;
verification of the adequacy of reports from the CFT/AML Officer provided to the Board of Directors and their compliance with the minimum requirements of the National Bank;
verification of the compliance of training programs for bank employees involved in the implementation of the CFT/AML policy.
Following the inspection of the activities of the bank's structural units for compliance with the CFT/AML internal control system, the internal auditor develops recommendations, which are also provided to the CFT/AML Officer for review.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
risks of financing criminal activity and money laundering;
violations of internal control programs and other internal bank documents in the field of CFT/AML;
violations of the legislation of the Kyrgyz Republic in the field of CFT/AML;
recommended measures necessary to eliminate and prevent identified violations.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 6. Officer Appointed for the Purpose of Organizing Internal Control for CFT/AML
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
taking appropriate measures to minimize the risk of the bank's involvement and its employees' participation in committing criminal (illegal) acts related to the financing of criminal activity and money laundering;
effective implementation of the legislation of the Kyrgyz Republic in the field of CFT/AML;
assisting the financial intelligence unit and the National Bank in fulfilling the tasks and functions provided for by the legislation of the Kyrgyz Republic in the field of CFT/AML.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
develops and submits for approval to the Board of Directors, in agreement with the bank's Management Board, the relevant internal control policy and brings this policy to the attention of all employees involved in its implementation;
ensures the implementation of the internal control policy and monitors the execution of the bank's internal regulatory documents on CFT/AML in accordance with this policy;
ensures the provision of information and data to the financial intelligence unit, including reports on operations (transactions) subject to control and reporting, in accordance with the requirements established by the legislation of the Kyrgyz Republic;
makes a decision on recognizing an operation (transaction) as suspicious and sending a report on a suspicious operation (transaction) to the financial intelligence unit, with subsequent notification to the bank's Management Board;
provides information and assists authorized representatives of the National Bank during their inspection checks of the bank's activities on issues falling within their competence under this Regulation and the bank's internal documents;
organizes training and consults bank employees involved in the implementation of the CFT/AML policy;
as necessary, but at least once a quarter, submits for consideration to the Board of Directors, with prior review by the bank's Management Board, a written report on the results of the implementation of the internal control policy for CFT/AML in the manner determined by the bank's internal documents;
assesses CFT/AML risks, including when introducing new banking products.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
receive necessary documents from managers and employees of the bank's units, including orders and other administrative documents issued by the bank's management and its units, accounting and cash settlement documents;
gain access to client and beneficial owner databases formed by the bank;
initiate obtaining additional information about the client, beneficial owner, and/or operation (transaction) to confirm the validity or refute suspicions of the client's involvement in financing criminal activity and money laundering;
in the established manner, enter the premises of the bank's units, as well as premises used for storing documents (archives), cash and valuables (cash vaults), and information databases;
make copies of received documents, including copies of electronic documents;
issue temporary instructions regarding the conduct of an operation (transaction), including orders to suspend an operation (transaction) and freeze an operation (transaction) and (or) funds, in accordance with the Regulation "On the Procedure for Suspending an Operation (Transaction), Freezing and Unfreezing an Operation (Transaction) and (or) Funds, Providing Access to Frozen Funds and Managing Frozen Funds", approved by Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated November 14, 2025 No. 739;
appeal to the bank's Board of Directors if necessary;
interact with and appeal to the Sharia Council(*).
Note: (*) Applies to banks operating in accordance with Islamic banking and finance principles.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
ensure the safety and return of documents received from the relevant bank units;
ensure the confidentiality of information obtained in the performance of their functions and not disclose data on the transfer of information to the financial intelligence unit;
notify the bank's Management Board of the recognition of an operation (transaction) as suspicious and the sending of a report on a suspicious operation (transaction) to the financial intelligence unit.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
an employee of the internal audit service;
an employee performing operational activities;
an employee performing activities where their independence is not ensured.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
know the legislation on CFT/AML issues;
have a clear understanding of banking products, operations, services, client operations, and potential risks characteristic of the bank's CFT/AML activities.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
results of monitoring compliance with requirements for identification, verification, and study of clients, as well as establishing the beneficial owner;
results of the analysis of client operations carried out to identify operations with signs of suspicious operations (transactions), including information regarding:
significant dynamics of funds movement in client accounts (active client accounts, bank employee accounts);
operations for the largest amounts;
purchase or sale of foreign currency to clients;
client operations whose amounts significantly exceed the turnovers characteristic of the client's usual activities;
cash operations (cash withdrawal, asset exchange, cash deposit to replenish a bank account through specialized peripheral devices of the bank);
operations for issuing loans and accepting deposits (term deposits);
operations with guarantees, letters of credit, and other contingent liabilities;
transfers without opening an account through money transfer systems, as well as through the SWIFT system (or other systems acting as main ones in banks);
client and bank operations for the purchase and sale of securities;
movement of funds of bank clients located in other countries;
on the provision of information to the financial intelligence unit in accordance with the requirements established by the legislation of the Kyrgyz Republic;
on the suspension of operations (transactions) and freezing of operations (transactions) and (or) funds, with a description of the justification for their suspension and freezing, the provision of information about them to the financial intelligence unit, and further work in accordance with legislation;
on compliance with measures for implementing the internal control program for CFT/AML by the bank's subsidiaries and affiliates located in the territory of the Kyrgyz Republic and abroad;
on monitoring the implementation of legislation and internal regulatory documents of the bank on CFT/AML in accordance with the bank's policy, their violation, and measures taken;
information on the results of work to eliminate violations noted in previous reports of the CFT/AML Officer submitted to the Board of Directors;
results of the work of employees involved in the implementation of the CFT/AML policy, measures taken to organize their training and consulting;
analytical information regarding:
possible interconnection of clients;
correspondent banks;
trust management operations (trust) of property under agreements with clients;
introduction of new banking products and technologies and risks associated with their introduction.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 7. Customer Due Diligence Using a Risk-Based Approach
(Chapter title as amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
assess, determine, document, and constantly update its risks regarding clients, countries, products, services, operations (transactions), and delivery channels for the purpose of allocating resources and reducing risks, including taking into account the results of national risk assessment and typical criteria for high and low risks;
in the established manner, provide information on identified risks to the National Bank and the financial intelligence unit;
develop and apply enhanced or simplified policies, as well as control procedures for managing and reducing risks.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 27, 2023 No. 2023-P-12/82-7)
27-1. The bank conducts customer and beneficial owner due diligence in cases and in the manner established by the legislation of the Kyrgyz Republic in the field of CFT/AML.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
27-2. The bank is obliged to identify the client (both permanent and one-time, both natural and legal person) in accordance with the legislation of the Kyrgyz Republic in the field of CFT/AML.
If an authorized person acts on behalf or on the instructions of the client, the bank is obliged to identify and verify this person, as well as check the relevant documents confirming the authority of such person.
The bank is obliged to verify the client by checking the accuracy of the information provided in the client questionnaires, using information and documents obtained from reliable sources. The bank is obliged to conduct client verification before and during the establishment of business relations/conducting a one-time operation.
When identifying and verifying a client (natural and legal person), a questionnaire is filled out in accordance with the requirements established in the Regulation "On the Procedure for Conducting Customer Due Diligence", approved by Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated November 14, 2025 No. 739.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
27-3. Banks are obliged to identify the beneficial owners of a client - a legal entity of the bank and apply measures to verify the identity of beneficial owners, using relevant information or data obtained from a reliable source to ensure that they know who the beneficial owner(s) is/are. To fulfill this requirement, banks are obliged to identify beneficial owners who directly or indirectly (through third parties) own more than 25% of the shares (stakes) of the legal entity.
In the absence of beneficial owners who directly or indirectly (through third parties) own more than 25% of the shares (stakes), or if there are doubts about the size of the beneficial owner's share (stakes), or doubts as to whether the person(s) with a controlling stake is/are the real beneficial owner(s) of the client - legal entity, banks are obliged to identify the beneficial owner(s) exercising control over the legal entity or formation by other means.
In limited cases, in the actual absence of beneficial owners who directly or indirectly (through third parties) own more than 25% of the shares (stakes) and the absence of beneficial owners exercising control by other means, banks are obliged to identify the natural person (natural persons) who has (have) the ability to control the actions of the client - legal entity due to positions held in the structure of the legal entity (responsible for strategic decision-making, exercising executive control, making decisions on financial matters). In this case, the beneficial owner's questionnaire is filled out for this person.
If foreign trusts or other legal entities are present in the ownership structure of a legal entity, banks are obliged to identify the beneficial owners of these legal entities. When identifying and checking/verifying the beneficial owner (in relation to clients that are legal entities), banks additionally use the following information:
in relation to trusts: personal data of the settlor, trustee, protector (if any), beneficiaries or group of beneficiaries, and any other natural person ultimately exercising actual control over the trust;
in relation to other types of legal entities: personal data of persons holding equivalent positions.
When identifying and verifying the beneficial owner, a questionnaire is filled out in accordance with the requirements established in the Regulation "On the Procedure for Conducting Customer Due Diligence", approved by Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated November 14, 2025 No. 739.
If the beneficial owner of the client is several natural persons, where each has a share (stakes) of more than 25% and/or exercises control by other means, then a questionnaire is filled out for each such person.
A scheme of the client's legal entity ownership (management) structure must be attached to the beneficial owner's questionnaire, which includes intermediate legal entities, up to the ultimate owners - natural persons, directly or indirectly (through third parties) owning more than 25% of the shares (stakes), and the degree of interconnection between the founders - legal entities and the beneficial owner. The ownership structure scheme must also display information regarding beneficial owners exercising control by other means and explain how such beneficial owners exercise this control. If foreign trusts or other legal entities are present in the ownership structure of a legal entity, they must also be displayed on the scheme.
The bank is obliged to understand the nature of the client's activities, as well as its ownership (management) structure.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The scope of due diligence measures must be determined taking into account the client's risk profile and the scale of business relations, in particular the level of risk, the purpose of business relations, the amount of operations carried out, the regularity or duration of business relations.
In case of establishing a high risk, the bank is obliged to apply enhanced customer due diligence measures. In case of establishing a low risk, simplified measures may be applied.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
28-1. When establishing business relations with clients/counterparties whose activities are related to virtual assets, as well as when carrying out operations related to virtual assets, the bank applies a risk-based approach taking into account the nature of the client's and (or) the client's counterparty's activities, the type and purpose of business relations, the channels used for operations, the jurisdiction, the degree of transparency of operations, the availability of information to the bank about the operation and its participants, as well as other circumstances relevant to the assessment of CFT/AML risk.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 28, 2026 No. 2026-P-14/44-1-(NPA))
28-2. The bank obtains and verifies information and documents necessary for conducting customer due diligence and assessing risks associated with business relations and operations specified in paragraph 10-1 of this Regulation, in accordance with the legislation of the Kyrgyz Republic in the field of CFT/AML and the bank's internal documents.
When assessing risk, the bank takes into account information about the nature of the client's activities, the purpose and intended nature of business relations, the source of origin of funds and other property, the expected volumes and types of operations, the countries (territories) of activity, the payment and other channels used, as well as other information available to the bank that is relevant for assessing CFT/AML risk.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 28, 2026 No. 2026-P-14/44-1-(NPA))
28-3. When establishing business relations with a client and (or) counterparty engaged in virtual asset activities, the bank takes reasonable and proportionate measures to the level of risk to establish its status, including checking for a license, registration, or other authorization in accordance with the legislation of the Kyrgyz Republic in the field of CFT/AML.
The absence or insufficiency of information about the counterparty's status is taken into account by the bank when assessing the risk level and serves as a basis for requesting additional information and documents, applying additional control measures, or other measures provided for by the legislation of the Kyrgyz Republic in the field of CFT/AML.
The bank takes into account the origin of virtual assets and the client's sources of funds when assessing risks associated with virtual asset operations.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 28, 2026 No. 2026-P-14/44-1-(NPA))
The bank is obliged to classify its clients taking into account risk criteria (high and low). To determine the risk level, it is necessary to at least consider the client's type of activity and location (origin) of the client and/or their business, as well as the operations they conduct, services provided, and the purpose of the client's payments. Typical criteria for high and low risks are established and published by the financial intelligence body. Banks may develop and apply criteria for medium risks.
Based on all information and documents allowing for the identification, verification, and study of the client, the bank assesses the risk level of the client's possible financing of criminal activity and legalization (laundering) of criminal proceeds, which is reflected in the client's questionnaire.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
collection of additional identification information and documents regarding the client from available and reliable information sources, as well as the use of this information when assessing the risk associated with the client;
collection of additional information about the client and beneficial owner for a deep understanding of the risk of possible involvement of such client and beneficial owner in criminal activity;
request for additional information from the client regarding the purpose and intended nature of business relations, as well as the source of the client's funds;
verification of the sources of the client's funds used within the framework of establishing business relations, in order to ensure that the funds are not proceeds from criminal activity;
regular updating of client and beneficial owner identification data using a risk-based approach, but at least once a year;
request from the client additional information clarifying the reason or economic sense of planned or conducted operations (transactions);
obtaining permission from the Board/Chairman of the Board or a Board member supervising the bank's operational activities (provided that such powers are delegated to him by the chairman of the bank's board), for establishing or continuing business relations with the client;
enhanced monitoring of business relations through daily monitoring of operations (transactions), analysis of information, consideration and accounting of the purpose of funds, using both automated information systems and manual mode, in order to identify signs of suspicious operations (transactions) and operations (transactions) that do not have an obvious economic sense or obvious legal purpose, as well as bringing the results of monitoring to the attention of the AML/CFT officer and the bank's Board;
proposal to conduct an operation (transaction) through a bank account, if the operation (transaction) is planned to be conducted without opening a bank account.
Assigning a high risk level to a client entails the bank applying enhanced client due diligence measures for effective management and/or reduction of risks.
Enhanced client due diligence measures must also be applied to clients from high-risk countries.
The bank needs to establish reasonable deadlines for the client to submit additional documents, including information about the counterparty, but not more than 10 (ten) working days in order to determine the economic feasibility and legality of the conducted operations, as well as the source of origin of the client's and beneficial owner's funds.
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated September 15, 2021 No. 2021-P-12/51-1, December 28, 2022 No. 2022-P-12/83-7, December 27, 2023 No. 2023-P-12/82-7, December 19, 2025 No. 2025-P-12/68-2-(NPA))
obtaining general information about the purpose and intended nature of business relations;
reducing the frequency of updating client and beneficial owner identification data;
monitoring client operations (transactions) in a simplified form using an automated system for checking operations (transactions) based on a limit determined by the bank.
Application of simplified measures for managing and reducing risks is not allowed if there are suspicions of the client's involvement in financing criminal activity and legalization (laundering) of criminal proceeds.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
use tools to determine whether the client or beneficial owner is a public official;
obtain written permission from the bank's Board for establishing or continuing (for existing clients) business relations with a public official, as well as when a public official conducts a one-time operation for an amount requiring due diligence;
establish the source of origin of funds and other property of the foreign public official;
conduct continuous and in-depth monitoring of business relations, including operations (transactions) carried out by the foreign public official, in the manner established for high-risk clients;
continuously update available information about foreign public officials.
The bank must apply the above measures to family members and close associates (close relatives, business partners, and official representatives) of a foreign public official.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
34-1. The measures specified in sub-paragraph 1 of paragraph 34 apply to national public officials and public officials of international organizations, as well as their families and close associates (close relatives, business partners, and official representatives).
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The bank may use open sources of information for establishing, monitoring, and verifying information regarding public officials.
The bank must update information obtained as a result of identification, verification, and study of the client, as well as the establishment of the beneficial owner, periodically, at least once a year in cases where the bank assesses the risk of the client's involvement in financing criminal activity and legalization (laundering) of criminal proceeds as high, and in other cases at least once every three years.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The bank takes into account risks associated with virtual assets, the use of distributed ledger technologies, as well as the possible use of banking services and products for settlements on virtual asset operations, including operations between users where the virtual asset service provider or other obligated entity does not participate in the transfer of virtual assets (P2P operations).
The bank takes reasonable and proportionate measures to the risk level to identify operations that show signs of possible use of banking services and products for settlements on virtual asset operations, within the information available to the bank when conducting client due diligence, monitoring business relations, and carrying out banking operations.
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated December 27, 2023 No. 2023-P-12/82-7, August 28, 2026 No. 2026-P-14/44-1-(NPA))
39-1. The bank is obliged to conduct ongoing client due diligence, which includes:
thorough analysis of operations (transactions) conducted by the client for their compliance with available information about the client, the nature and type of economic activity, the client's financial position, the source of origin of funds, property, assets, the level and nature of risks associated with the client and their operations;
keeping information and documents obtained as a result of client due diligence up-to-date and in an appropriate form, by regularly checking the accuracy and completeness of client information, as well as its timely updating, primarily in relation to high-risk clients.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
39-2. If the bank is unable to apply appropriate client due diligence measures, the bank must not enter into business relations, not carry out the operation, terminate business relations, and in the established manner send a corresponding message to the financial intelligence body within 1 (one) working day from the date of the decision to refuse client service.
In cases where the bank is convinced that conducting client due diligence would lead to the disclosure of information about emerging suspicions, the bank does not take client due diligence measures, suspends the suspicious operation (transaction), and sends a message about the suspicious operation (transaction) to the financial intelligence body.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
39-3. If, during the establishment of business relations or in the course of business relations with a client, or when conducting one-time operations (transactions), suspicions arise that the operations (transactions) are related to the financing of criminal activity and legalization (laundering) of criminal proceeds, the bank must apply the following measures:
conduct identification and verification of the client and beneficial owner, regardless of any exceptions or established thresholds;
conduct a comprehensive analysis of the business relations or operation (transaction) and make a decision on recognizing the business relations or operation (transaction) as suspicious;
suspend the suspicious operation (transaction) and, within five hours from the moment of recognizing the operation (transaction) as suspicious in the established manner, send a message about the suspicious operation (transaction) to the financial intelligence body;
suspend or terminate business relations with the client.
In cases where the bank is convinced that conducting client due diligence would lead to the disclosure of information about emerging suspicions, the bank does not take client due diligence measures, suspends the suspicious operation (transaction), and sends a message about the suspicious operation (transaction) to the financial intelligence body.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
39-4. In case of absence or insufficiency of information and documents, the bank requests additional information and documents, applies additional client due diligence measures and other measures provided for by the legislation of the Kyrgyz Republic in the field of AML/CFT and the bank's internal documents. If it is impossible to conduct client due diligence, the bank acts in accordance with paragraph 39-2 of this Regulation.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated August 28, 2026 No. 2026-P-14/44-1-(NPA))
39-5. When carrying out cash withdrawal operations and transit operations on accounts of legal entities and individual entrepreneurs, the bank, applying a risk-based approach, is obliged to take into account the following signs of increased risk:
a significant share of turnover on the client's bank account is cashed out, while the volume and frequency of cash withdrawal operations do not correspond to the nature, scale, or type of their economic activity, as well as other information about the client available to the bank;
cash withdrawal operations are carried out in a short period after they are credited to the client's bank account, including on a systematic basis, in the absence of obvious economic sense or inconsistency of such operations with the nature, scale, or type of the client's economic activity;
funds are received from one or more counterparties with subsequent cash withdrawal in the absence of obvious economic sense or inconsistency of such operations with the nature and scale of the client's financial and economic activity;
cash withdrawal operations are carried out regularly in small amounts or by performing several interrelated operations in the absence of obvious economic sense;
funds are credited to the client's bank account from one or more persons with their subsequent transfer within a short period to third parties, including to foreign states, in the absence of obvious economic sense or inconsistency of such operations with the nature and scale of the client's financial and economic activity (transit operations);
a short period has passed since the date of state registration of the legal entity or individual entrepreneur or the opening of a bank account, while significant volumes of operations are carried out on the bank account that do not correspond to the duration, nature, and scale of the client's financial and economic activity;
the volume and frequency of funds received from foreign states for cash withdrawal do not correspond to the declared activity and scale of the client's financial and economic activity or the nature of their relationship with the foreign sender;
significant volumes of cash are deposited into the client's bank account with their subsequent transfer within a short period to third parties, including to foreign states, in the absence of obvious economic sense or inconsistency of such operations with the nature and scale of the client's financial and economic activity (transit operations);
corporate bank cards are systematically used predominantly for receiving cash that does not correspond to the nature, scale, and purposes of the client's financial and economic activity.
Quantitative values of increased risk indicators, including the share of cash withdrawal operations in the total volume of client operations, the period between receipt and subsequent cash withdrawal or transit operation, as well as other quantitative indicators are determined by the bank in internal regulatory documents taking into account the type (nature) and scale of clients' activities, their risk profile, as well as the results of the bank's AML/CFT risk assessment, and the results of national and sectoral risk assessments.
39-6. Upon identifying factors with signs of increased risk, as provided for in paragraph 39-5 of this Regulation, the bank is obliged to conduct additional operation verification measures, including:
analysis of the nature of the client's relationship with the sender/recipient of funds, the purpose of the payment, and its compliance with the client's financial and economic activity;
establishing the source of origin of the received funds and obtaining and analyzing documents and information confirming the economic basis of the operation;
establishing the purpose of the cash withdrawal operation and its compliance with the nature and scale of the client's financial and economic activity;
analysis of the preceding movement of funds, including the period between their receipt on the bank account and the client's request for cash withdrawal.
In case of the client's refusal to provide the required documents within the established deadlines, the bank must refuse to conduct the operation on the account.
If, based on the results of the additional check, the bank has suspicions that the operations (transactions) are related to the financing of criminal activity and legalization (laundering) of criminal proceeds,
the bank must apply the following measures:
suspend the suspicious operation (transaction) in the manner and for the period established by the legislation of the Kyrgyz Republic in the field of AML/CFT, and/or
suspend or terminate business relations with the client.
39-7. The bank must ensure the accounting of cash withdrawal operations and transit operations on accounts of legal entities and individual entrepreneurs for which signs of increased risk, as provided for in paragraph 39-5, have been identified, and the results of applying measures to reduce the identified risks.
The accounting must contain at least information on the quantity and volume of cash withdrawal operations and transit operations:
for which signs of increased risk have been identified;
which were not conducted on the grounds provided for by legislation in the field of AML/CFT;
which were recognized as suspicious and messages about them were sent to the authorized financial intelligence body.
Information provided for in this paragraph is used by the bank to assess the effectiveness of applied measures for managing and reducing AML/CFT risks associated with cash withdrawal operations and transit operations, and is provided to the National Bank upon its request.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated October 01, 2026 No. 2026-P-12/48-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 8. Identification of Operations (Transactions) Subject to Control and Reporting
studying conducted operations on the client's account to ensure that the client's activity corresponds to the information the bank has about the client, their business, and the risk level for that client;
if necessary, clarifying the origin of funds credited to the client's account;
analyzing all complex or unusually large operations that do not have an obvious or visible economic or legal purpose;
recording and documenting all information received by the bank and, if necessary, transmitting this information to the financial intelligence body.
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA), December 19, 2025 No. 2025-P-12/68-2-(NPA))
The following operations (transactions) are subject to control and reporting:
suspicious operations (transactions);
operations (transactions) with individuals or legal entities from high-risk countries. The list of operations (transactions) with individuals or legal entities from high-risk countries subject to reporting to the financial intelligence body is determined in the manner established by the Cabinet of Ministers of the Kyrgyz Republic;
operations (transactions) carried out by an individual who has served a sentence for carrying out legalization (laundering) of criminal proceeds, criminal activity, as well as for financing such activity;
operations (transactions) with cash and non-cash funds for an amount equal to or exceeding the threshold amount.
The list of operations (transactions) with cash and non-cash funds and their threshold amount are established by the Cabinet of Ministers of the Kyrgyz Republic.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated December 27, 2023 No. 2023-P-12/82-7, December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
Chapter 9. Recording, storage and transmission of information obtained during internal control to the financial intelligence unit
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The Bank's Board is responsible for the timely implementation of further actions, including suspending the operation (transaction) and/or terminating business relations with the client.
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated September 15, 2021 No. 2021-P-12/51-1, December 19, 2025 No. 2025-P-12/68-2-(NPA))
Attention! By Resolution of the Board of the National Bank of the Kyrgyz Republic dated September 15, 2021 No. 2021-P-12/51-1-(NPA), amendments were made to paragraph 3 in the state language.
(As amended by Resolutions of the Board of the National Bank of the Kyrgyz Republic dated December 28, 2022 No. 2022-P-12/83-7, December 19, 2025 No. 2025-P-12/68-2-(NPA))
message about a suspicious operation (transaction) - within 5 (five) hours from the moment the operation (transaction) is recognized as suspicious in the established manner;
message about an operation (transaction) with individuals or legal entities from high-risk countries - within 2 (two) business days from the date of such operation (transaction);
message about operations (transactions) carried out by an individual who has served a sentence for the legalization (laundering) of criminal proceeds, criminal activities, as well as for financing such activities - within 2 (two) business days from the date of such operations (transactions);
message about a cash and non-cash operation (transaction) for an amount equal to or exceeding the threshold amount - within 3 (three) business days from the date of such operation (transaction).
The list of cash and non-cash operations (transactions) and their threshold amount are established by the Cabinet of Ministers of the Kyrgyz Republic.
The above messages are sent to the financial intelligence unit in accordance with the requirements of the Regulation "On the Procedure for Submitting Information and Documents to the Financial Intelligence Unit of the Kyrgyz Republic", approved by Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated November 14, 2025 No. 739.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
The bank is not entitled to inform clients about the transmission of information to the financial intelligence unit, except in cases provided for by legislation in the field of CFT/AML.
Information and documents containing data about the client, beneficial owner, including business correspondence, as well as about client operations (transactions), the results of any conducted analysis, and other data obtained during the inspection, in accordance with this Regulation, must be stored for at least 5 (five) years after the termination of relations between the bank and the client/completion of a one-time operation (transaction) with the client.
Information must be stored in sufficient volume to allow for the reconstruction of the characteristics of the completed operation (transaction) or to trace funds by reconstructing the entire chain of the operation (transaction) and, if necessary, to be used as evidence in investigations and court proceedings in accordance with the criminal procedure legislation of the Kyrgyz Republic.
The bank provides information and documents to authorized law enforcement agencies, national security agencies, and prosecutor's offices of the Kyrgyz Republic in accordance with the requirements of the legislation of the Kyrgyz Republic.
(As amended by Resolution of the Board of the National Bank of the Kyrgyz Republic dated December 19, 2025 No. 2025-P-12/68-2-(NPA))
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Source: National Bank of the Kyrgyz Republic — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works