Arxo Findings Register · Arxo Law

ARXO-2026-0090 · Reported

Client asset rules give regulatory roles to 'the AIFC' (the Centre) where the regulator, the AFSA, is meant

The Glossary defines AIFC as the Astana International Financial Centre (a territory/regime). COB nevertheless says: firms must demonstrate grounds 'to the AIFC's satisfaction' (8.2.11, 8.3.8); Client Money may be paid out in circumstances 'otherwise authorised by the AIFC' (8.2.13(e)); disclosure of 'other Distribution Event stipulated by the AIFC' (8.2.18(a)(ii)). The parallel collateral disclosure (8.3.2(d)) says 'stipulated by the AFSA', and the Glossary Distribution Event (c) is a direction by the AFSA.

Proposed correction

Please replace "AIFC" with "AFSA" in COB 8.2.11, 8.2.18(a)(ii) and 8.3.8, and state in COB 8.2.13(e) whether "authorised by the AFSA" or "authorised under the AIFC Acts" is meant.

Jurisdiction
Kazakhstan — AIFC
Act
AIFC Conduct of Business Rules (COB), V17
Place
COB 8.2.11 last paragraph
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
2026-10-24

Evidence

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

An Authorised Firm must be able to demonstrate to the AIFC's satisfaction the grounds upon
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.2.11 last paragraph · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
paid out in circumstances that are otherwise authorised by the AIFC.
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.2.13(e) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
Event stipulated by the AIFC
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.2.18(a)(ii) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
AFSA, any excess Collateral will be sold
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.3.2(d) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy

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 8.2.11 last paragraph; COB 8.2.13(e); COB 8.2.18(a)(ii); COB 8.3.2(d). 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. 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.

Documents and reproduction

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-2026-0090, https://arxo.io/findings/ARXO-2026-0090/ (status as of 2026-10-24). Data: ARXO-2026-0090.json.