Amendments No. 14 apply COB 8.2 to Money Service Providers but 'Client Money' (8.2.1, Glossary) still covers only Investment Business money

Since Amendments No. 14 (13 January 2026), COB 8.1.2 and 8.1.4 require an Authorised Firm that Provides Money Services to comply with COB 8.2, and PMS 9.1 sends a Money Service Provider to a Client Money Account "as prescribed under COB 8". The intended scheme follows from these rules. But COB 8.2.1, the heading of COB 8.2 ("Client Money: Investment Business") and the Glossary definition of "Client Money" still describe only Money held in connection with Investment Business, so the definition and the heading do not match the rule that applies them.

Proposed correction

Please align the Client Money definition (COB 8.2.1 and the Glossary) and the heading of COB 8.2 with COB 8.1.4 and PMS 9.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Conduct of Business Rules (COB), V17

Place

COB 8.1.4

Record

Discrepancy

Class

Amendments

Where it arose

The amending 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.

the carrying on of Investment Business or Provides Money Services in or from the AIFC must comply with COB 8.2.

carrying on of Investment Business in or from the AIFC is Client Money, except Money which is:

Accounts within one day of receipt.

An Authorised Firm Providing Money Services must comply with PMS 9 when paying or placing

In COB 8, has the meaning given in Rule 8.2.1;

at the end of the Business Day following the day on which it was received

Provides Money Services in or from the AIFC must comply with COB 8.2.

How to check it without Arxo's tools

1. Open Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) and find COB 8.1.4; COB 8.2.1; COB 8.2.5; COB 8.2.5 Guidance. Compare the text with the quotation above. A copy is kept in this register: ae99fece8c925210-cob_v17_13.01.2026-1.pdf (SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6, copy of the official file).
2. Open AIFC Glossary (GLO), V23 and find Glossary V23 'Client Money'. 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).
3. Open AIFC Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026) and find PMS 9.1(1). Compare the text with the quotation above. A copy is kept in this register: 333935eb310b57bc-pms-rulebook-25.05.2025_-v.1.pdf (SHA-256 333935eb310b57bcba51ab477b3e11e65a88e7ccf094eda06bc4e023e4fdac1a, copy of the official file).
4. Open AFSA Consultation Paper AFSA-PSRD-CSP-2026-0005: Targeted Amendments to the AIFC Rules (15.07.2026) and find Consultation Paper AFSA-PSRD-CSP-2026-0005 (15.07.2026, closed, not adopted as of 25.10.2026), Annex, COB 8.1.4(1). Compare the text with the quotation above. A copy is kept in this register: 05a2ed115abcc1ab-AFSA-PSRD-CSP-2026-0005.pdf (SHA-256 05a2ed115abcc1ab90a39c74ced2414b5a157d49522442ec652e29947cb34872, copy of the official file).
5. 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.

Documents and reproduction

• Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026)
• AIFC Glossary (GLO), V23
• AIFC Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026)
• AFSA Consultation Paper AFSA-PSRD-CSP-2026-0005: Targeted Amendments to the AIFC Rules (15.07.2026)

History

1. 2026-10-24Confirmed 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-2026-0087, https://arxo.io/findings/ARXO-2026-0087/ (status as of 2026-10-25). Data: ARXO-2026-0087.json.