Arxo Findings Register · Arxo Law

ARXO-2026-0053 · Reported

GEN Schedule 1, paragraph 4(2): two activity names that do not exist

Paragraph 4(2) incorporates into Managing a Collective Investment Scheme activities constituting "Dealing as Agent" and "Dealing as Principal". Schedule 1 defines "Dealing in Investments as Agent" (paragraph 2) and "Dealing in Investments as Principal" (paragraph 1); the Glossary does not define the two shorter names. The wording has been there since the initial 2017 release. The draft in Consultation Paper AFSA-PSRD-CSP-2026-0001 (Annex 2) corrects a third name in the same paragraph ("Managing Assets" to "Managing Investments") but keeps these two.

Proposed correction

Please use the defined names "Dealing in Investments as Agent" and "Dealing in Investments as Principal"; the change could be made in the same amendment.

Jurisdiction
Kazakhstan — AIFC
Act
AIFC General Rules (GEN), V20
Place
Schedule 1 para 4(2) / page 45
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
2026-10-25

Evidence

Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.

To the extent that any activity under (1) constitutes Managing Assets, Providing Fund
Normative text · AIFC General Rules (GEN), V20 · Schedule 1 para 4(2) / page 45 · retrieved 2026-10-23 · SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681 · copy
Managing Investments means managing on a discretionary basis assets belonging to another
Normative text · AIFC General Rules (GEN), V20 · Schedule 1 para 3 / page 45 · retrieved 2026-10-23 · SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681 · copy

How to check it without Arxo's tools

  1. Open AIFC General Rules (GEN), V20 and find Schedule 1 para 4(2) / page 45; Schedule 1 para 3 / page 45. Compare the text with the quotation above. A copy is kept in this register: e863a30c73072b03-gen-v20.pdf (SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681, copy of the official file).
  2. 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

Reported to

DateInstitutionChannelReference
2026-10-27Astana Financial Services Authority (AFSA)e-mail

Responses

No response recorded.

History

  1. 2026-10-23Confirmed by Arxo
  2. 2026-10-27Entered in the register
  3. 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0053, https://arxo.io/findings/ARXO-2026-0053/ (status as of 2026-10-25). Data: ARXO-2026-0053.json.