What this is. A structured self-assessment against eight obligations that sit at the centre of the AIFC AML, CFT and Sanctions Rules: the MLRO, the business-wide risk assessment, customer due diligence and beneficial ownership, ongoing monitoring, sanctions screening, suspicious-transaction reporting, the virtual-asset Travel Rule, and independent audit with training and record-keeping. Each question names the rule it maps to.
How it scores. It counts how many of the eight you can honestly place as fully in place, and shows the specific gap and the rule behind each area you cannot. It does not produce a risk percentage, and it does not predict a fine, a licence action or forced measures. Those do not follow automatically from a control gap, and any number claiming otherwise would be invented.
On the citations. References are to the AIFC AML, CFT and Sanctions Rules as amended, effective 1 January 2025. AFSA renumbers on amendment, so treat rule numbers as pointers to the current rulebook, not a substitute for reading it. The primary framework is published by AFSA: afsa.aifc.kz, AIFC AML/CTF legal regime.
What Black Sea is. Black Sea is an independent financial-crime compliance advisory that builds and runs the AML programme behind a regulated operator's licence. It is not a law firm, not a software vendor, and holds no licence itself. This tool is general information, not legal advice, and it is not an AFSA or AIFC product, nor endorsed by either.