Y. Khamidullina, K. Mychka Practical Advantages of Dispute Resolution by the AIFC International Arbitration Centre // Chambers and Partners - 2026.11.12
International Arbitration Centre (the "IAC") of the Astana International Financial Centre (the "AIFC") is becoming ever more popular platform for the resolution of major commercial disputes. Its popularity is supported by the increased number of arbitration cases and widespread use of arbitration clauses providing for submission of disputes for consideration by the IAC.
According to official statistics of the IAC, the annual number of arbitration cases increased steadily: from 1 case in 2019 and 10 cases in 2020 to 109 cases in 2021, 170 cases in 2022, 203 cases in 2023, 243 cases in 2024 and 303 cases in 2025. These figures reflect the number of arbitration cases for each individual year rather than the cumulative number of cases since the IAC commenced operations. Relevance of the AIFC's institutions is also evidenced by the widespread use of the respective contractual clauses: according to the AIFC [1], provisions on submission of disputes for consideration by the AIFC Court or the IAC were included in more than 13,000 commercial contracts.
The possibility of applying to the IAC is not limited by disputes between the AIFC participants. Article 14 of the AIFC Constitutional Statute [2] provides for connection between dispute consideration by the IAC with presence of an arbitration agreement between the parties and does not make it dependent upon the parties' status as the AIFC participants. Therefore, the parties may provide for submission of disputes to the IAC, which may be subject to arbitration proceedings, including under contracts not directly connected with activities in the AIFC.
Flexible procedure, confidentiality and possibility to choose arbitrators are traditional advantages of arbitration. However, practical importance of choosing the IAC is not limited by these aspects. Equally important are legal implications revealing beyond the dispute consideration on the merits: what court will exercise judicial control and assist arbitration; what are the grounds, based on which an arbitral award may be revoked, and how will it be enforced? It is worth mentioning here that relevant mechanisms depend not only on the choice of arbitration institution, but also on the seat of arbitration, and with respect to enforcement issues – also on jurisdiction where it is required to enforce an award.
These specific features are in many ways conditional upon the special legal regime of the AIFC. According to Article 4 of the AIFC Constitutional Statute, the current laws of the AIFC are based on the Constitution of the Republic of Kazakhstan (the "Kazakhstan") and include the AIFC Constitutional Statute, acts of the AIFC, and Kazakhstan current laws with respect to the issues not regulated by the AIFC Constitutional Statute and acts of the AIFC.
The legal fundamentals of arbitration in the AIFC are determined by the AIFC Arbitration Regulations [3], while the procedure for conducting arbitration proceedings administered by the IAC is regulated by the IAC Arbitration and Mediation Rules [4].
According to Articles 7 and 9 of the AIFC Arbitration Regulations, if the seat of arbitration is the AIFC, such arbitration proceedings fall under provisions of the AIFC Arbitration Regulations and requirements of the Arbitration Law [5] do not apply.
It is important to distinguish the choice of the IAC as an arbitration institution administering the proceedings and the choice of the AIFC as the seat of arbitration.
These concepts are not identical. According to Article 15.1 of the IAC Arbitration and Mediation Rules, the parties may themselves determine the seat of arbitration. If the parties fail to agree upon the seat of arbitration and a dispute is regulated by the AIFC laws, the seat of arbitration is the AIFC. In other cases, the seat of arbitration is determined by the panel of arbitrators subject to positions of the parties and all case circumstances.
Accordingly, the very indication of the IAC as an arbitration institution does not always mean that the seat of arbitration will be the AIFC. If the parties count on application of a special procedural regime of the AIFC, it is reasonable to expressly secure the seat of arbitration in an arbitration clause.
For the purposes of this article arbitration at the IAC means arbitration proceedings administered by the IAC with the seat of arbitration in the AIFC.
Below we will consider the main advantages of such arbitration, which have significant practical importance for the parties: procedure for recognition and enforcement of arbitral awards at the AIFC Court, consideration by the AIFC Court of applications to set aside arbitral awards, and non-application of the requirement on obtainment of consent from the authorized governmental agency to conclusion of an arbitration agreement with certain categories of disputes stipulated by the Arbitration Law.
1. Enforcement of the IAC Awards Without the Necessity to Apply to the Kazakhstan State Courts of general jurisdiction
One of practical advantages of arbitration at the IAC is the opportunity of recognition and enforcement of an arbitral award at the AIFC Court stipulated by the AIFC acts without applying to the Kazakhstan state court for issuance of an enforcement order (writ of execution).
According to the general rule established by Article 55 of the of the Arbitration Law, if an arbitral award is not performed on a voluntary basis, a claimant needs to apply to a state court of Kazakhstan for enforcement. Accordingly, before transition to enforcement proceedings, the claimant must undergo a separate judicial procedure and obtain an enforcement order from the state court.
As regards the arbitral awards of the IAC, the AIFC acts provide for a special mechanism. According to Articles 45-47 of the AIFC Arbitration Regulations, a party in whose favor an award has been issued may apply for its recognition and enforcement directly to the AIFC Court. In addition, Article 40 of the AIFC Court Regulations provides for the possibility of enforcement of arbitral awards issued with the seat of arbitration in the AIFC and approved by the AIFC Court both in the territory of the AIFC and within the rest territory of Kazakhstan.
An application must attach the original arbitral award and arbitration agreement or their properly certified copies. If relevant documents are made not in English, the AIFC Court may request for their notarized translation. When considering the application, the AIFC Court checks for the presence of grounds to reject recognition or enforcement, the exhaustive list of which is established by Article 47 of the AIFC Arbitration Regulations.
The procedure is regulated in more detail by the AIFC Court Rules [6].
According to rule 27.40 of the AIFC Court Rules, an application for recognition or enforcement of an arbitral award may be filed without preliminary notification of the other party. If a respective order has been issued without notification, such party may apply to set aside the order within 14 days after serving it or within any other period established by the AIFC Court. No enforcement is allowed until expiration of the said term and, if an application to set aside has been filed on time, until its final consideration (rule 27.44 of the AIFC Court Rules).
After completion of the said procedure, an arbitral award, with respect to which the AIFC Court issued an enforcement order, may be enforced in the territory of Kazakhstan under the same procedure as a relevant resolution or order of the AIFC Court (rule 27.49 of the AIFC Court Rules). To commence enforcement proceedings a claimant may apply to the AIFC Court for an execution order, which will be subsequently submitted to the enforcement authority of Kazakhstan. Thus, the Execution Order is issued by the AIFC Court rather than by a Kazakhstan state court. Article 13.8 of the AIFC Constitutional Statute expressly provides that decisions of the AIFC Court are to be enforced in Kazakhstan in the same manner and on the same terms as judicial acts of Kazakhstan courts. In addition, Article 9.1.1-1 of the Law on Enforcement Proceedings and the Status of Enforcement Agents [7] includes writs of execution issued on the basis of decisions of the AIFC Court in the list of enforcement documents.
At the same time, legal regulation on this issue is not completely unequivocal and may provide for different interpretations.
Article 14.3 of the AIFC Constitutional Statute provides that awards of the IAC must be recognized and enforced in Kazakhstan under the same procedure and based on the same conditions as awards of other arbitrations operating under the Kazakhstan legislation. In case of literal interpretation, such reference may imply application of general procedure providing for the necessity to apply to a state court for an enforcement order.
However, the AIFC Arbitration Regulations, AIFC Court Regulations and the AIFC Court Rules provide for a special procedure for recognition and enforcement of arbitral awards at the AIFC Court. Furthermore, national legislation on enforcement proceedings expressly refers to the enforcement orders issued based on resolutions of the AIFC Court to execution orders.
The mechanism officially applied by the AIFC Court [8] also provides for subsequent interaction of a claimant directly with the enforcement authority of Kazakhstan without the participation of state courts.
Thus, in case of applying the mechanism, which is stipulated by the AIFC acts and applied in practice, a claimant does not need to initiate separate proceedings at a Kazakhstan state court. The issues of recognition of an arbitral award and its admission to enforcement are resolved by the AIFC Court, after which the claimant may obtain an execution order and apply to the Kazakhstan enforcement authority.
Nevertheless, this advantage should not be taken as complete absence of judicial control. The AIFC Court checks for the presence of grounds for rejection of recognition or enforcement of an award stipulated by the AIFC Arbitration Regulations and a debtor is given an opportunity to challenge an order issued without notifying the debtor.
The practical meaning of this mechanism lies in the fact that judicial control is exercised within a special legal regime of the AIFC without the necessity to apply to the Kazakhstan state courts. Accordingly, this not only reduces the number of procedural stages required to move from the issuance of an arbitral award to its actual enforcement but also lowers the risk of origination of additional procedural obstacles, including a rejection to enforce based on formal grounds at the stage of considering a relevant application by a state court.
2. Setting Aside an Arbitral Award by the AIFC Court on Limited Grounds
Another practical effect of choosing the AIFC as the seat of arbitration is a special procedure for judicial control over an issued arbitral award.
According to Article 44 of the AIFC Arbitration Regulations, application for setting aside an arbitral award issued during proceedings with the seat of arbitration in the AIFC may be filed only to the AIFC Court. Such application is the only stipulated method of challenging an arbitral award for the purpose of setting it aside.
In this case, proceedings on the issue of setting aside the arbitral award neither serve as an appeal, nor provide for repeated consideration of the dispute on the merits.
The party's disagreement with conclusions of arbitration regarding the actual circumstances, evaluation of evidence or application of law does not serve itself as a ground for setting aside the arbitral award.
Powers of the AIFC Court are limited to examination as to presence of grounds expressly and completely stipulated by Article 44 of the AIFC Arbitration Regulations.
The said grounds generally reproduce the approach of Article 34 of the UNCITRAL Model Law on International Commercial Arbitration [9]. They may be divided into two groups.
The first group includes the circumstances, presence of which must be proved by a party seeking to have an award set aside. Specifically, this includes legal incapacity of a party or invalidity of an arbitration agreement; absence of proper notification on appointment of an arbitrator or arbitration proceedings, or failure to demonstrate its position; consideration by arbitration of issues not covered by an arbitration agreement; and non-conformity of the panel of arbitrators or arbitration procedure to the parties' agreement or applicable requirements of the AIFC Arbitration Regulations. If resolutions on the issues that are beyond the limits of an arbitration agreement may be separated from other provisions of an arbitral award, only a respective part of the award may be set aside.
The second group covers the grounds, which may be established by the AIFC Court: non-arbitrability of the dispute subject in accordance with the current laws of the AIFC and contradiction of an arbitral award to the public policy of Kazakhstan.
An application to set aside an arbitral award must be filed within 3 months of the date a party receives an arbitral award or, if the party filed an application for correction, interpretation or supplementation of an award to the panel of arbitrators in accordance with Article 43 of the AIFC Arbitration Regulations, within 3 months of the date of considering such application by the panel of arbitrators. At the same time, the parties may agree in writing to a longer period.
The AIFC Arbitration Regulations also provide for a mechanism aimed at preservation of an arbitral award. If so requested by a party, the AIFC Court may suspend the proceedings relating to the setting aside of an award for a period determined by the AIFC Court and grant an opportunity to the panel of arbitrators to resume proceedings or take other measures capable of removing the grounds for setting aside the award. Thus, presence of a curable procedural violation must not automatically lead to the entire award being set aside.
The list of independent grounds stipulated by the AIFC Arbitration Regulations is narrower as compared with the list established by the Arbitration Law.
Besides the grounds generally in line with the UNCITRAL Model Law, Article 52.1.5) of the Arbitration Law provides for an award to be set aside if a court judgment or an arbitral award has previously entered into legal force in a dispute between the same parties, regarding the same subject and based on the same grounds, or if there has been a ruling issued by court or arbitration on termination of proceedings in connection with the claimant's abandonment of the claim. There is no such independent ground in Article 44 of the AIFC Arbitration Regulations.
The practical meaning of this difference lies in the fact that, if the seat of arbitration in the AIFC, a party challenging an award may not refer to the said circumstances as an independent ground for setting it aside.
Furthermore, an application is considered by the AIFC Court within a special legal regime and without applying to governmental authorities of Kazakhstan.
This does not mean that arbitral awards at the IAC enjoy absolute immunity from being set aside. The AIFC Court preserves the powers to verify validity of an arbitration agreement, observation of the key procedural guarantees, limits of competence of the panel of arbitrators, dispute arbitrability, and compliance of the award with the public order of Kazakhstan. However, such control is limited by the grounds established by the AIFC Arbitration Regulations and does not allow reconsidering an award only in connection with the fact that one of the parties does not agree with its result.
In total, the exclusive competence of the AIFC Court and exhaustive list of grounds for setting aside an arbitral award ensure considerable certainty for the parties regarding the procedure for judicial challenging of an arbitral award. For the parties, this circumstance also mitigates the risk of an award being set aside based on additional grounds stipulated by the general legislation of Kazakhstan on arbitration and allows determining the court and legal regime in advance, under which further control over award will be exercised.
3. No Necessity to Obtain Consent from the Authorized Governmental Agency in Disputes Involving Governmental Agencies
Another considerable difference of arbitration with the seat of arbitration in the AIFC is non-application of a special requirement of the Arbitration Law on obtainment of consent from the authorized governmental agency to conclusion of an arbitration agreement in case of participation of governmental agencies and certain public sector entities.
According to Article 8.10 of the Arbitration Law, arbitration may not consider disputes between individuals and/or legal entities of Kazakhstan acting as one party and governmental agencies, state enterprises or legal entities where 50% and more voting shares or participatory interests directly or indirectly belong to the state acting as the other party in case there is no consent of the authorized agency for a relevant industry with respect to republic property or a local executive authority with respect to municipal property.
To obtain such consent, a governmental agency or a relevant public sector entity must send a request to the authorized agency, specifying the forecasted costs in connection with arbitration proceedings. The request must be considered within 15 calendar days, following which a written message must be provided on irrevocable consent or motivated refusal. Article 9.4 of the Arbitration Law expressly requires that the obtained consent must be reflected in the very arbitration agreement.
Accordingly, within the common legal regime of Kazakhstan such consent is not only an internal administrative process of the public party. Its absence gives rise to the risk of challenging validity of an arbitration agreement and competence of the panel of arbitrators. If an award has already been issued, relevant objections may be filed in proceedings to set it aside on the basis of Article 52 of the Arbitration Law, as well as in case of considering the issue of recognition and enforcement of an award.
Although an obligation to apply for consent is imposed on the governmental agency or a relevant public sector entity, consequences of a failure to perform it affect both parties. Specifically, a counterparty may encounter a situation where the other party with state participation refers to the absence of the obtained consent for the purpose of challenging the arbitration clause, competence of the panel of arbitrators or issued award after a dispute has arisen.
In case of the seat of arbitration in the AIFC, a special legal regime applies.
According to Articles 7 and 9 of the AIFC Arbitration Regulations, requirements of the Arbitration Law do not apply to arbitration proceedings conducted in accordance with the AIFC Arbitration Regulations in case the seat of arbitration is in the AIFC.
Accordingly, the requirements of Articles 8.10 and 9.4 of the Arbitration Law on obtainment of consent from the authorized governmental agency and its reflection in an arbitration agreement do not apply either.
This approach is confirmed by the practice of the AIFC Court. In the case of Success K LLP v. Ministry of Healthcare of Kazakhstan [10], a defendant challenged validity of an arbitration agreement by referring to the absence of consent from the authorized agency for state property to conclusion of an arbitration agreement.
The AIFC Court dismissed relevant arguments of the defendant, having established that the said requirement of national legislation does not apply to the arbitration agreement in question. The court established that the AIFC laws applied to arbitration, including the AIFC Arbitration Regulations, Article 7 of which excludes application of requirements of the Arbitration Law.
Based on this ground, the AIFC Court concluded that Article 8.10 of the Arbitration Law was not applicable to the arbitration agreement under consideration and absence of consent stipulated thereby did not entail invalidity of the arbitration clause. The court also dismissed the argument that similar consent was allegedly required directly under the Law on State Property [11], because such interpretation would restore the requirement excluded by Article 7 of the AIFC Arbitration Regulations and would deprive this rule of its practical importance. As a result, the Ministry's application to set aside the award was dismissed and the award of the IAC was recognized and enforced.
Thus, the choice of the AIFC as the seat of arbitration allows avoiding application of the special requirement of national legislation on obtainment of consent from the authorized agency, absence of which may entail challenging of the arbitration agreement and issued award under the common legal regime of Kazakhstan.
This is of great practical importance for business. The parties do not need to include an additional lengthy stage of applying to the authorized agency in the process of coordination of an agreement, and a private counterparty does not depend on whether the governmental agency fulfilled the procedure imposed on it. This simplifies the process of coordination of an arbitration agreement and increases stability of the selected dispute resolution mechanism after origination of disagreements.
At the same time, this advantage does not exempt a governmental agency or a state enterprise from the necessity to comply with other requirements of legislation, constituent documents or internal procedures, which may apply to conclusion and performance of a master contract. Furthermore, for the special regime of the AIFC to be definitely applied, the parties need to expressly specify the AIFC as the seat of arbitration in an arbitration agreement.
4. Possibility of Prompt Protection of Assets and Application of Security Measures
One of significant practical advantages of arbitration at the IAC is the opportunity of taking security measures before final resolution of a dispute. This circumstance is very important for commercial disputes, since even an arbitral award, which is favorable for a claimant, may turn out to be inefficient if a defendant withdraws assets, disposes of disputed property or takes other actions during the proceedings, which will hinder any subsequent enforcement.
Article 27 of the AIFC Arbitration Regulations regulates the powers of the panel of arbitrators on adoption of security measures, conditions of their application, and procedure for judicial assistance with ensuring of their fulfillment. Article 24 of the IAC Arbitration and Mediation Rules allows the panel of arbitrators to take security measures upon a party's application in the form of an order or an arbitral award, including injunctions.
Additional protection is granted by Article 23 of the IAC Arbitration and Mediation Rules, which provides for an opportunity to compel a party to take certain actions or refrain from them in order to preclude from the loss of practical efficiency of a future arbitral award as a result of withdrawal of assets or other circumstances.
Peculiarity of the mechanism at hand is that a party in whose favor a security measure has been adopted may apply directly to the AIFC Court for its enforcement in case of presence of a written permit from the panel of arbitrators (paragraph 24.4 of the IAC Arbitration and Mediation Rules and paragraph 27.31 of the AIFC Court Rules).
5. Appointment of an Emergency Arbitrator for Adoption of Urgent Security Measures
The procedure for appointing an Emergency Arbitrator is of certain practical importance. The need for urgent protection may arise before the main panel of arbitrators is formed. Specifically, this is possible in a situation where there is an imminent threat of withdrawal of funds, alienation of disputed property or other actions that may cause significant damage to one of the parties.
Formation of the panel of arbitrators requires certain time, since it includes appointment of arbitrators and resolution of potential issues of their independence and impartiality. During the said period, a party may need urgent procedural protection. An application for appointment of an Emergency Arbitrator may be filed concurrently with an application for commencement of arbitration proceedings or after filing it but before formation of the main panel of arbitrators. The Emergency Arbitrator may adopt the required temporary measures, including interlocutory orders before conducting a full-scale hearing (Article 32 of the IAC Arbitration and Mediation Rules).
6. Expedited Arbitration Proceedings with the Possibility to Issue an Award Within Six Months
Article 31 of the IAC Arbitration and Mediation Rules provides for a possibility of conducting proceedings under an expedited procedure in case of presence of one of the following conditions: amount of dispute does not exceed the equivalent of USD 5 million, parties agreed application of the expedited procedure or a case is characterized by exceptional urgency. When determining the amount of dispute, not only the initial claims of a claimant are taken into consideration but also counterclaims, and applications for setoff.
Application of the expedited procedure is not automatic. A decision is made by the IAC Registrar subject to the position of the parties, dispute nature and purpose of ensuring fair resolution of a case without groundless delays and costs. As regards the expedited proceedings, a case is normally submitted to a sole arbitrator, unless the IAC Chairman decides otherwise.
The key specific feature of the procedure is the term of issuing the final arbitral award, which must be no more than six months after the date of forming the panel of arbitrators, unless the Registrar extends this term in case of exceptional circumstances.
The advantage of the expedited procedure is especially great for the disputes over debts recovery, payment for the supplied goods, work performed or provided services, when the main circumstances are confirmed by documents and there is no need to conduct complicated expert examinations or interrogate many witnesses. The expedited proceedings may help reduce a period of uncertainty, cutting expenses for legal support, and contributing to an earlier award, which may be presented for enforcement.
7. Practical Conclusions for Business
The specifics at hand should be considered early at the stage of concluding a contract, since the content of an arbitration clause directly affects not only the procedure for consideration of a potential dispute, but also subsequent challenging and enforcement of an arbitral award.
In particular, the choice of the IAC with expressly determined seat of arbitration in the AIFC allows determining in advance a court that will exercise control over an arbitral award, grounds based on which it may be revoked, and a special recognition and enforcement mechanism which may be applied in the territory of Kazakhstan.
For the companies stipulating subsequent enforcement of an award in Kazakhstan, practical importance of such choice lies in the opportunity to conduct judicial procedures preceding enforcement within the institutions of the AIFC.
An application to set aside an award is considered only by the AIFC Court based on an exhaustive list of grounds, and the enforcement mechanism, which is stipulated by the AIFC acts and applied in practice, allows a claimant to apply directly to the enforcement authority of Kazakhstan on the basis of an execution order of the AIFC Court without the necessity to additionally apply to a state court of Kazakhstan for an enforcement order. This allows reducing the number of involved judicial instances and determining a legal regime in advance, which will be applied to exercise control over the award.
This mechanism may be of special importance when concluding contracts with governmental agencies, state enterprises and companies with state participation. Determining the AIFC as the seat of arbitration allows avoiding the application of a special requirement on obtainment of consent from the authorized agency stipulated by Article 8.10 of the Arbitration Law.
The advantages considered do not originate automatically only if indicating the IAC as an arbitration institution. If the parties count on application of a special procedural regime of the AIFC, an arbitration clause must expressly provide for submission of disputes for consideration by the IAC and specify the AIFC as the seat of arbitration. Otherwise, if there are no grounds for determining the AIFC as the seat of arbitration by default as provided for by the IAC Arbitration and Mediation Rules, this issue may be left for consideration by the panel of arbitrators, and the applicable regime for judicial control and challenging of an award will be less predictable.
Therefore, when agreeing an arbitration clause, it is reasonable to consider the status and powers of a counterparty, expected location of its assets, probable place of enforcement of a future award, and presence of mandatory corporate or administrative approvals. It is also necessary to bear in mind that more direct access to enforcement proceedings does not guarantee actual recovery, which specifically depends upon the presence of assets with a debtor, against which it will be possible to initiate recovery proceedings.
Thus, as regards complicated commercial projects, transactions involving the public and quasi-public sector, and contracts, which provide for enforcement of awards in the territory of Kazakhstan, a correct arbitration clause providing for consideration of disputes at the IAC with the seat of arbitration in the AIFC under the expedited arbitration proceedings may ensure more consistent and predictable process of dispute resolution, judicial control over an arbitral award, and its subsequent admission to enforcement. This is one of the key practical advantages of such choice for business.
According to the official statistics of the AIFC Court and the IAC, as of October 2026, they completed and enforced more than 5,500 cases, including more than 1,000 arbitral awards. According to the published data of the said institutions, the index of enforcement of court judgments and arbitral awards in the territory of Kazakhstan made 100% [12].
[1] Please see AIFC Annual Report 2024, available at https://aifc.kz/annual-reports/aifc-annual-report-2024/; AIFC Court & IAC Present 2025 Results & Future Plans, please see https://iac.aifc.kz/ru/novosti-ru/sud-mftsa-i-mats-predstavili-rezultaty-za-2025-god-i-plany-na-budushhee/; [2] Constitutional Law No. 438-V of the Republic of Kazakhstan "On the Astana International Financial Centre" dated 7 December 2015, as amended; [3] AIFC Arbitration Regulations, as approved by the Resolution of the AIFC Management Council dated 5 December 2017 (official name – AIFC Arbitration Regulations Resolution of the AIFC Management Council – https://aifc.kz/legal-framework/aifc-arbitration-regulations/), as amended; [4] Arbitration and Mediation Rules, as approved by the Chairman of the International Arbitration Centre dated 19 September 2022 (official name – Rules on Arbitration and Mediation at the International Arbitration Centre – https://aifc.kz/legal-framework/iac-arbitration-and-mediation-rules-2022/), as amended; [5] Law No. 488-V of the Republic of Kazakhstan "On Arbitration" dated 8 April 2016, as amended; [6] AIFC Court Rules, as approved by the Chief Justice of the AIFC Court on 1 January 2018 (official name – AIFC Court Rules 2018 – https://aifc.kz/legal-framework/aifc-court-rules-2018/?ysclid=mu6lok19j6852462631), as amended; [7] Law No. № 261-IV of the Republic of Kazakhstan "On Enforcement Proceedings and Status of Court Enforcement Officers" dated 2 April 2010, as amended; [8] Enforcement, official website of the AIFC Court and IAC, which contains a direct indication on interaction with the enforcement authority without the participation of local courts https://iac.aifc.kz/services/enforcement/; [9] UNCITRAL Model Law on International Commercial Arbitration (1985), as amended – https://uncitral.un.org/en/texts/arbitration/modellaw/commercial_arbitration; [10] Resolution of the first instance court of the AIFC dated 24 January 2022 in the case No. AIFC-C/CFI/2021/0008, (1) Success K LLP v Ministry of Healthcare of the Republic of Kazakhstan; (2) Ministry of Healthcare of the Republic of Kazakhstan v Success K LLP, paragraphs 15–28 and 33–38, https://iac.aifc.kz/judgments/case-no-8-of-2021-1-success-k-llp-v-ministry-of-healthcare-of-the-republic-of-kazakhstan-and-2-ministry-of-healthcare-of-the-republic-of-kazakhstan-v-success-k-llp/?ysclid=mu6l6ocurw230905741; [11] Law No. 413-IV of the Republic of Kazakhstan "On State Property" dated 1 March 2011, as amended. [12] AIFC Court & IAC Present 2025 Results & Future Plans https://court.aifc.kz/news/aifc-court-iac-present-2025-results-future-plans/.