COB 8.5.13(2) and the 16.2 table use the undefined 'Insurance Bank Account'

COB 8.5 requires Client Money to be held in "Client Money Accounts" (8.5.6, 8.5.9). COB 8.5.13(2) requires records of "all sums withdrawn from the Insurance Bank Account as a result of credit taken under COB 8.5.12", and the table in COB 16.2 repeats it. "Insurance Bank Account" is not defined in COB or in the Glossary and is used nowhere else. The term has been in COB since the first version (then COB 11.8.12). The meaning (the Client Money Account) can be recovered from 8.5.9 and 8.5.12.

Proposed correction

Please replace "Insurance Bank Account" with "Client Money Account" in COB 8.5.13(2) and in the table in COB 16.2.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Conduct of Business Rules (COB), V17

Place

COB 8.5.13(2)

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.

withdrawn from the Insurance Bank Account as a result of credit taken under COB 8.5.12

ensure that Client Money is held in one or more Client Money Accounts with one or more

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 8.5.13(2); COB 8.5.9(a). 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

• 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)

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-2026-0091, https://arxo.io/findings/ARXO-2026-0091/ (status as of 2026-10-24). Data: ARXO-2026-0091.json.