Official Clarification of the Company Regarding Interaction with the State Authorities of the Republic of Kazakhstan

In December 2025, a month and a half after Integration ICN KZ had obtained from the Ministry of Artificial Intelligence and Digital Development of the Republic of Kazakhstan a Permit for the Issuance and Circulation of Asset-Backed Digital Assets issued by the state regulator for the purpose of granting access to the functionalities of the Bitbon System infrastructure through the Bitbon digital asset (No. KZ31VWS00000002 dated October 29, 2025) the Committee for Digital Assets and Breakthrough Technologies of the Ministry of Artificial Intelligence and Digital Development of the Republic of Kazakhstan conducted an inspection of the Company’s activities as a licensed entity in accordance with the Inspection Checklist in the field of asset-backed digital assets. Pursuant to item 2 of the Inspection Checklist, the inspection covered the “existence and compliance of the Decision on the Issuance of Asset-Backed Digital Assets.” Despite the fact that, at the present stage, the Company has only just commenced comprehensive preparations for the start of operations under the obtained Permit, including, inter alia, the development of a set of documents required for the publication of the Decision on the issuance of the asset-backed Bitbon digital asset in accordance with the requirements of the legislation of the Republic of Kazakhstan the absence of such a Decision is unjustifiably interpreted by the inspecting authority as a violation of Article 7 of the Law of the Republic of Kazakhstan “On Digital Assets in the Republic of Kazakhstan.”

Based on the results of the inspection, an Order to Remedy Violations was issued, stating that, due to the absence at the time of the inspection of a Decision on the issuance and circulation of asset-backed digital assets, the Company is required to cease activities related to the issuance and circulation of the digital asset.

Integration ICN KZ has submitted a formal objection to the inspection results to the Committee for Digital Assets and Breakthrough Technologies. In addition, an official complaint has been filed with the Ministry of Artificial Intelligence and Digital Development of the Republic of Kazakhstan regarding the unlawful actions of officials of the Committee for Digital Assets and Breakthrough Technologies, which are attributable to a misunderstanding of certain provisions of the Law of the Republic of Kazakhstan “On Digital Assets in the Republic of Kazakhstan.”

Given that the lack of established practical experience in the field of asset-backed digital assets in the Republic of Kazakhstan (as well as globally) necessitates further development and improvement of the regulatory framework, certain procedures require clarification and a unified approach by all participants in the process, both the business community and the state regulator. In view of the above, the fact that Integration ICN KZ obtained the first Permit in this field in the Republic of Kazakhstan since the entry into force of the Law of the Republic of Kazakhstan “On Digital Assets in the Republic of Kazakhstan” has become a matter of close attention for state executive authorities and has created a precedent giving rise to non-standard situations.

We emphasize that our Company adheres to the principle of full legal transparency. In order to eliminate any uncertainty and resolve the situation promptly, the Company publishes all necessary information on its official information resources and strengthens its cooperation with the state authorities of the Republic of Kazakhstan. Non-standard situations are inevitable and constitute an integral part of establishing real practice in any new sector of the economy. For its part, the Company is prepared to provide comprehensive assistance to the relevant state executive authorities of the Republic of Kazakhstan in the development of practical approaches to the market of asset-backed digital assets, with a view to preventing the occurrence of similar situations for market participants in the Republic of Kazakhstan in the future.

As the Regional Operator of the Bitbon System, Integration ICN KZ strictly adheres in its activities to a policy of transparency and openness, both in building business relationships and in its interactions with state authorities, acting exclusively within the framework of applicable legislation.

We consider it necessary to note that attempts by certain representatives of the state executive authorities of the Republic of Kazakhstan to obstruct the lawful activities of Integration ICN KZ run counter to the country’s Strategic Course as defined in the Address to the People of Kazakhstan by the President of the Republic of Kazakhstan, Kassym-Jomart Tokayev, entitled “Kazakhstan in the Era of Artificial Intelligence: Current Challenges and Their Solutions through Digital Transformation,” published in September 2025.

While maintaining active cooperation with the developer company of the digital platform responsible for implementing legal and organizational-technological measures to ensure the integration of the requirements of the national legislation of the Republic of Kazakhstan in the field of asset-backed digital assets and AML into the core services of the Bitbon System, we continue comprehensive preparations for the commencement of our activities as part of the implementation of the Strategy for the Development of the regional infrastructure of the Bitbon System in the Republic of Kazakhstan.

All up-to-date information is available on the Company’s official information resources.