ARXO-2026-0035 · Reported
AML Guidance refers to Chapter 6 for risk assessments; they are in Chapters 4 and 5
Guidance (k) after AML 4.3.3 and Guidance (j) after AML 6.3.4 refer to the customer risk assessment "under Chapter 6", and the sanctions Guidance (g) to "the risk assessments under Chapters 5 and 6". AML 1.5(d) places the customer risk assessment in Chapter 5; Chapter 6 contains none.
Proposed correction
Please align the risk-assessment references in the Guidance with the business and customer risk assessment provisions (Chapters 4 and 5).
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML)
- Place
- Guidance on RBA (k), after AML 4.3.3
- Record
- Discrepancy
- Class
- Text of the act
- Where it arose
- The text of the act
- Arxo's conclusion
- Confirmed
- Official text
- Unchanged at last check
- Last checked
- 2026-10-23
Evidence
Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.
will also feed into the Relevant Person’s risk assessment of its customers (see Chapter 6).money laundering risks identified under Chapter 6.taking into account the risk assessments under Chapters 5 and 6.Chapter 5 explains the concept of Customer Risk Assessments (“CRA”).
How to check it without Arxo's tools
- Open AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML), as of 15 December 2024 and find Guidance on RBA (k), after AML 4.3.3; Guidance on conducting CDD (j), after AML 6.3.4; Guidance on Government, Regulatory and International Findings (g); AML 1.5(d). Compare the text with the quotation above. A copy is kept in this register: 6ca352e46b7bd314-aml.pdf (SHA-256
6ca352e46b7bd314846207558a7131c1525cb9ad14aa6a9ba9d6cd2d2edd35b1, copy of the official file). - The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.
How this finding was made
AI agents read the official texts, turned the provisions concerned into executable rules and ran the comparison; they also drafted this record. A person at Arxo checked the finding and approved the report before it was sent (2026-10-27).
Responsible institutions
- Astana Financial Services Authority (AFSA) — author of the AIFC Rules
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-27 | Astana Financial Services Authority (AFSA) |
Responses
No response recorded.
History
- 2026-10-23Confirmed by Arxo
- 2026-10-27Entered in the register
- 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0035, https://arxo.io/findings/ARXO-2026-0035/ (status as of 2026-10-23). Data: ARXO-2026-0035.json.