Regulatory risk in Kazakhstan has certainly been impacted by the implementation of the Subsoil and Subsoil Use Code in 2017. The law has made positive changes - the main one being that the system has changed from a contractual process to a licensing system, resulting in an improved risk profile for the jurisdiction in certain key risk areas. However, some of those more problematic provisions from a risk perspective, previously present under the 2010 legal framework, have unfortunately been retained. These include local content requirements, priority rights of the State over strategic resources and incredibly restrictive provisions around transfers and changes of control. The introduction of the licensing system alone has also not proved sufficient to remove the significant levels of government discretion over the granting of rights – with broad caveats in the law providing considerable room for arbitrary decision-making. Investors will be right in thinking that there is an improved landscape for entry into the jurisdiction but would be wise to approach with caution and their eyes wide open to the regulatory risks which still remain.