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25.11.2025,
в 17:00
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In 2025, the Specialized Interdistrict Administrative Court of Almaty reviewed 17 identical administrative cases against Altyn Bank JSC, which were consolidated into a single proceeding. During a documentary inspection conducted by employees of the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market, violations of the AML/CFT Law were identified. Specifically, Altyn Bank failed to submit information on money and/or property transactions subject to financial monitoring, including suspicious transactions.
According to the administrative offense protocols filed by Agency employees, the bank’s AML system automatically identified payments made by its client, CATU Tech LLP, as suspicious. However, the bank did not submit an FM-1 report to the AFM within the timeframe established by Article 13 of the AML/CFT Law — within 24 hours of identifying the transaction as suspicious.
These violations indicate that Altyn Bank failed to report transactions under code “1061,” as required by Regulation No. 13. The bank’s actions (or inaction) constituted an administrative offense: failure to provide information on transactions subject to financial monitoring, as defined in Articles 4(3) and 4(5) of the AML/CFT Law, punishable under Article 214(2) of the Administrative Code.
For reference, code 1061 refers to payments and money transfers to non-residents of Kazakhstan under import contracts that do not involve the physical movement of goods into Kazakhstan or across its territory.
Altyn Bank representatives denied wrongdoing, stating that although the AML system automatically flagged CATU Tech transactions as potentially suspicious, a deeper review showed that goods were delivered under the contract with Chill High Tech Limited. Therefore, not all transactions were deemed suspicious. The bank argued that the additional analysis confirmed supply fulfillment for contracts with EURO TRADE GROUP LIMITED, Chill High Tech Limited, Edgecore Networks Corporation, and Switech Development Limited. Altyn Bank therefore requested that the case be dismissed for lack of an administrative offense.
The court rejected these arguments, noting that the transactions were automatically flagged under code 1061 and had signs of suspicious activity: “There are indications the company was created for intermediary or transit operations. Funds are received only from one company — B4COM TECHNOLOGIES LLC, registered in the Russian Federation — and then transferred to South Korea, Hong Kong, and Taiwan.”
CATU Tech was registered on March 17, 2022 — less than a month after the start of Russia’s “special military operation” in Ukraine. The contract items — electronic components and parts — did not cross Kazakhstan’s borders. The bank failed to provide comprehensive documents proving the required in-depth analysis of each suspicious operation, as dictated by the monitoring rules.
The court concluded that Altyn Bank had committed an administrative offense by failing to submit required information on transactions subject to financial monitoring.
Under Article 58(1) of the Administrative Code, penalties must be imposed separately for each offense. The total calculated fine was 25,105,600 tenge. However, due to the legal cap of 2,000 monthly calculation indices (MCI) for large businesses under Article 44(2), the fine was reduced to 6,000 MCI — 22,152,000 tenge.
The court ruled:
“To hold Altyn Bank JSC (a subsidiary of China Citic Bank Corporation Limited) liable under Article 214(2) of the Code of Administrative Offenses with an administrative fine of 22,152,000 tenge.”
Altyn Bank appealed, but the Almaty City Court upheld the original decision.
Who Received Payments From CATU Tech, Which Received Money From Russia’s B4COM TECHNOLOGIES?
Contract with Chill High Tech Limited (Hong Kong, China)
Contract CH-CT-01/122022 dated 06.12.2022 for electronic components.
Goods do not enter Kazakhstan. Total contract value: under USD 5 million.
Payments from CATU Tech at Altyn Bank to Chill High Tech Limited:
Contract with EURO TRADE GROUP LIMITED (South Korea)
Contract ET-CH/001 dated 15.12.2022.
Goods do not enter Kazakhstan. Max value: USD 7 million.
Payments:
Contract with Edgecore Networks Corporation (Taiwan)
Contract ENC-CT-01/2023 dated 22.02.2023.
Goods do not enter Kazakhstan. Max value: USD 10 million.
Payments (all flagged under code 1061):
28.03.2023 — 297,000
28.03.2023 — 300,000
30.03.2023 — 115,324
30.03.2023 — 288,912
30.03.2023 — 300,000
17.04.2023 — 165,840
17.04.2023 — 49,654
26.04.2023 — 598,765
26.04.2023 — 91,904
Contract with Switech Development Limited (Hong Kong, China)
Contract SW-B4/2023-01 dated 11.04.2023.
Goods do not enter Kazakhstan. Max value: USD 10 million.
Payment:
All these transactions are cited in the court ruling.
In total, Altyn Bank failed to report suspicious transactions totaling USD 6,626,254 — over 3.5 billion tenge at the current rate.
CATU Tech Company Background
According to data from adata.kz:
Ownership changes:
The company paid only 15.8 million tenge in taxes over three years. Aside from Siyanov, it has no employees.
Who Sponsored or Used CATU Tech as a Sanctions-Bypassing Shell Company?
According to Russian sources, B4COM TECHNOLOGIES is a tech company specializing in the development and production of advanced IT, telecom, and IoT equipment, founded in 2015. It develops solutions based on SDN, 4G, 5G, 6LoWPAN, and other technologies.
Its products are publicly described on the company’s website. It’s clear why the company would be subject to sanctions.
Thus, the actions of CATU Tech and Altyn Bank could expose Kazakhstan to secondary sanctions. CATU Tech still appears active based on tax records. The suspicious transactions occurred only in 2023.
CATU Tech has other noteworthy details, which Hronika.kz will cover in the next publication.
Translation: Chat GPT.
Image: 2gis.kz.
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