National Bank of Kyrgyzstan proposes sanctions screening for all cash foreign exchange transactions

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The National Bank of Kyrgyzstan proposes requiring supervised institutions to screen clients against sanctions lists for every one-off cash foreign exchange transaction, regardless of amount. The draft resolution, aimed at aligning regulatory acts with Kyrgyz legislation and FATF standards, has been opened for public discussion.
Sanctions Screening Proposal
The National Bank of Kyrgyzstan published the draft resolution for public discussion in August 2026. It would require supervised institutions to check each client, and where applicable their beneficial owner, against sanctions lists for every one-off cash foreign exchange transaction, regardless of the amount. When updating client data, institutions would also compare beneficial owner information with state systems and send discrepancies to the financial intelligence unit. Kaktus Media reported that current checks apply only to clients who buy or sell large sums, while the new requirement would cover commercial banks and exchange bureaus.
Late Fine Penalty
The draft clarifies administrative offense procedures, including ending proceedings if the person held liable dies. If a fine is not paid voluntarily by the deadline, the National Bank proposes charging 1% of the fine for each day of delay, up to the limit set by the Code of Offenses. Information on sending the ruling to court bailiffs would be entered into the automated information system AIS ERPN, the unified register of offenses.
New SFO and Audit Rules
The National Bank proposes extending several regulations to specialized financial organizations after changes to their legal status. SFOs would be required to have automated accounting and reporting systems. Internal audit employees at banks and supervised non-bank financial-credit institutions would need a certificate in counter-terrorist financing and anti-money laundering issued by a financial intelligence unit training center. The document was published in August 2026.