CRTR and First Credit Bureau Case: Prosecutor Demands Up to 15 Years as Defense Pleads for Full Acquittal

On October 6, 2026, judicial inquiry concluded in an Almaty court in the criminal proceedings regarding alleged state losses exceeding 2 billion tenge arising from commercial cooperation between JSC "Centre for Workforce Development" (CRTR, an agency under the Ministry of Labor and Social Protection of the Republic of Kazakhstan) and LLP "First Credit Bureau" (PKB). The trial advanced to closing arguments (pleadings), where the state prosecutor requested custodial sentences, while defense attorneys demanded complete acquittal of the defendants due to the absence of the corpus delicti and event of a crime. All defendants pleaded not guilty. The court has not yet rendered a verdict, and proceedings remain ongoing.

All statements are provided strictly for informational purposes based on public court proceedings and official records. The Qazaqstan Chamber of Actuaries examines this precedent exclusively through the lens of actuarial science, risk mathematics, and actuarial loss methodology, without expressing judicial opinions on guilt or innocence.

Background of the Dispute: Collaboration & Chronology (2020–2026)

The institutional relationship between CRTR and credit bureaus originated with the national digital transition of social and retail credit underwriting in Kazakhstan:

• 2020 — Integration Framework: To automate borrower solvency verification during retail bank credit origination, CRTR provided access to pension contribution ledgers from the Unified Information System of the Social and Labor Sphere. In December 2020, the commercial revenue split was renegotiated from 75/25 to 65/35, reflecting the private bureau's substantial capital investments in building IT gateway infrastructure and engineering 20 new digital validation services (expanding the suite from 8 to 28).
• 2023–2024 — Supervisory Inquiries: State supervisory audits compared PKB's commercial terms (65/35) against CRTR's contract with the State Credit Bureau (GKB, 70/30), mechanically interpreting the 10-percentage-point difference as counterfactual lost state revenue.
• 2025 — Criminal Proceedings & Detentions: Kazakhstan's Anti-Corruption Agency initiated formal proceedings, detaining former CRTR executives (ex-vice-ministers Daulet Argandykov and Akmadi Sarbasov) and PKB CEO Ruslan Omarov on charges of abuse of office, bribery, and deployment of malicious software.
• 2026 — Almaty Judicial Proceedings: Over extensive hearings, the court examined gateway architecture, witness testimony from enterprise IT engineers, and forensic economic audits. On October 6, 2026, the trial advanced to closing arguments.

Sentences Requested by the Prosecution and Civil Claim

The public prosecutor asked the court to find all five defendants guilty and impose the following custodial sentences in medium-security correctional facilities:

• Ruslan Omarov, former General Director of the First Credit Bureau: 15 years of imprisonment, accompanied by a lifetime ban on civil service and a three-year disqualification from executive roles in information technology organizations (charged with aiding and abetting abuse of office, aiding and abetting the use of malicious software, and bribery);
• Daulet Argandykov, former head of CRTR (and ex-vice-minister): 12 years of imprisonment, a lifetime civil service ban, and a three-year IT executive ban (charged with abuse of office, aiding and abetting, using malicious software, and bribery);
• Akmadi Sarbasov, who succeeded Argandykov as head of CRTR (also an ex-vice-minister): 8 years of imprisonment and a lifetime ban on civil service (charged with abuse of office and receiving a bribe);
• Tauke Bolatbayev, former department director at CRTR: 4 years and 8 months of imprisonment, with a three-year IT industry ban;
• Akzhol Doshimov, CRTR software engineer: 4 years and 8 months of imprisonment, with a three-year IT industry ban.

The prosecutor also sustained a civil claim totaling approximately 2.088 billion ₸: seeking roughly 1.959 billion ₸ jointly and severally from Argandykov and Omarov, and approximately 129.85 million ₸ jointly and severally from Argandykov, Omarov, and Sarbasov.

The Prosecution's Case

The prosecution's core allegation centers on the restructuring of commercial contract terms in December 2020. Under the original service framework, CRTR received 75% of fee revenue, with PKB retaining 25%. Via a supplemental addendum, the parties adjusted the split to 65% for CRTR and 35% for PKB. State investigators classified the 10-percentage-point difference as "unrealized state revenue" (lost profit), drawing a mechanical comparison with CRTR's contract with the State Credit Bureau (GKB), which retained a 70/30 distribution.

A second allegation involves the alleged deployment of malicious software. The prosecution asserts that CRTR engineers implemented an artificial delay mechanism (utilizing the standard Thread.sleep command) to throttle queries routed to the State Credit Bureau by 1 to 3 seconds, ostensibly redirecting bank credit scoring queries to PKB. A third charge alleges a $75,000 bribe delivered in June 2025 in exchange for continued commercial patronage.

Defense Arguments: Loss Quantification and Technical Evidence

Attorneys representing Ruslan Omarov, Rashid Tenizbayev and Elena Kubasheva, presented an extensive technical and forensic rebuttal, petitioning for immediate release and full acquittal:

• Equating Missed Profit with Real Loss: The defense argued that investigators conflated actual balance-sheet damage with theoretical lost revenue. Direct comparison with GKB is fundamentally flawed: the private credit bureau independently financed and engineered software infrastructure for 20 new digital services (expanding the portfolio from 8 to 28), while funding commercial marketing, bank staff training, and 24/7 technical operations. Consequently, CRTR's lower percentage share (65%) applied to a exponentially larger transaction volume generated substantially greater absolute revenues for the state enterprise, enabling CRTR to eliminate state budget subsidies, achieve financial self-sufficiency, and disburse corporate dividends to the government.
• Forensic Accounting Inaccuracies: The economic expert report erroneously incorporated value-added tax (VAT) and complimentary credit reports (which generated zero commission) into the loss calculation, while omitting analysis of actual banking transaction ledgers.
• Rebuttal of Malicious Code: The defense demonstrated that Thread.sleep is a standard multi-threading utility in the Java programming language, not malware. Case records contain zero production server logs or monitoring telemetry demonstrating that the throttling code was ever compiled, deployed, or executed during the relevant timeframe. Furthermore, an expert witness mistakenly confused milliseconds with seconds, exaggerating theoretical latency by a factor of 1,000. National Information Technologies JSC (NIT) formally confirmed in writing to the court that enterprise incident monitoring logs from 2023 to 2025 recorded no instances of malicious code injection or deliberate throughput throttling.
• Redundant VPN Channels: The secondary secure tunnel was a standard disaster recovery failover mechanism deployed automatically when the state gateway suffered downtime, preventing paralysis across nationwide retail online banking credit lines.
• Absence of Bribery Evidence: Surveillance recordings from the meeting venue establish that Omarov never transferred money, packages, or bags. The $8,000 discovered on Sarbasov was documented as a private interpersonal loan from Argandykov, and the alleged $75,000 sum was neither seized nor corroborated.

The case is regarded across Kazakhstan's legal and fintech sectors as a landmark judicial test defining the boundaries of commercial risk, public-private partnerships, and state registry monetization.

Actuarial Takeaway: The CRTR and First Credit Bureau litigation holds profound methodological significance for actuarial loss modeling and operational risk governance. For pricing actuaries and risk executives, the dispute highlights the vital distinction between direct balance-sheet loss and speculative counterfactual lost profit. Quantifying damages without incorporating demand elasticity and investment multipliers (expanding from 8 to 28 services) distorts actuarial cash flow principles. Furthermore, the proceedings underscore the indispensable necessity of immutable audit logging to substantiate system availability and latency within automated scoring and underwriting workflows.