Glossary, "Money Laundering Reporting Officer": points to GEN 2.3.4, which is omitted

The Glossary defines the MLRO as "the individual performing the Designated Function identified at GEN 2.3.4". GEN 2.3.4 now reads "[intentionally omitted]"; the MLRO is a Controlled Function under GEN 2.2.5-1 and must be held by an Approved Individual (GEN 2.1.1(1)(d)).

Proposed correction

Please update the GEN reference in "Money Laundering Reporting Officer" (now GEN 2.2.5-1) and keep it distinct from the wider MLRO requirements under AML 13.1 for DNFBPs and auditors.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Glossary (GLO), V23

Place

Glossary V23, entry "Money Laundering Reporting Officer"

Record

Discrepancy

Class

Amendments

Where it arose

The amending 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.

The individual performing the Designated Function identified at GEN 2.3.4.

2.3.4. [intentionally omitted]

2.2.5-1 Money Laundering Reporting Officer

How to check it without Arxo's tools

1. Open AIFC Glossary (GLO), V23 and find Glossary V23, entry "Money Laundering Reporting Officer". Compare the text with the quotation above. A copy is kept in this register: 041617346ad87a9f-glo-v23.pdf (SHA-256 041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45, copy of the official file).
2. Open AIFC General Rules (GEN), V20 and find GEN V20 2.3.4 / page 18; GEN V20 2.2.5-1 / page 16. 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).
3. 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

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-2026-0063, https://arxo.io/findings/ARXO-2026-0063/ (status as of 2026-10-23). Data: ARXO-2026-0063.json.