Kyrgyzstan – CM PB

2024, Cross-border, Update

Country Manual Private Banking – Kyrgyzstan BRP Update 2024

BRP has updated its Country Manual Private Banking for Kyrgyzstan out of bank’s country of establishment (DEF, RS, BT and RT)

Source of changesAnswers
Law / RegulationYes
New Position of the AuthoritiesNo
Evolution of Expert’s InterpretationNo

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed following consultation with our local counsel. We can confirm that there have been no relevant regulatory changes to the general cross-border framework since the last publication of this Country Manual.

Nevertheless, there have been changes in the Kyrgyz currency controls (“Foreign Exchange Controls”): Recent amendments of the Constitutional Law on the National Bank of the Kyrgyz Republic have removed individuals from the list of those required to report on the bank accounts opened offshore. Legal entities, however, are still obliged to submit notification on any bank account/deposit opened in a foreign bank to the National Bank of Kyrgyzstan. By “legal entity” the law includes branches and representative offices of foreign legal entities located and registered in the Kyrgyz Republic.

Non-material changes

Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

Implications for business relations with third parties

With respect to the provision of documentation to the EAM (such as documentation on the Bank’s banking and investment services, investment research and financial analysis or recommendation lists), our country manual now distinguishes between the provision to the EAM for remittance to the end client on one hand and the provision to the EAM for the EAM’s own professional purposes on the other hand. The answers have been amended accordingly.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

BT Short Comparaison

BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “KYRGYZSTAN” in the Target Country Field.

For more information, please contact us: info@brpsa.com

Geneva, April 3rd, 2024