MAR 5.5.3: the closing words "prior to conducting a Market Sounding" also cover the record of disclosures in (c), which can only be completed after the sounding

MAR 5.5.3 lists four steps (a) to (d) and then, on a separate line after (d), the words "prior to conducting a Market Sounding". Laid out this way, the words govern the whole list. Steps (a) and (b) already carry their own timing. Step (c) requires a record of the disclosures, including "the date and time of each disclosure", which cannot be complete before the sounding. The AFSA online text joins the closing words to (d) instead. The second sentence of (c) also asks for the record to be given to "the competent authority", while (d) names the AFSA.

Proposed correction

Please make clear that the closing words apply to (a) only, or delete them, since (a) and (b) already set the timing; and use "the AFSA" in (c), or delete the second sentence of (c) as a repeat of (d).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Market Rules (MAR), V13

Place

MAR V13, 5.5.3(c) (rule), page 54

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.

The disclosing market participant must provide that record to the competent authority upon request; and

provide its written record to the AFSA upon request; prior to conducting a Market Sounding.

the identity of the potential investors to whom the information has been disclosed

provided that the Person making the disclosure complied with the requirements in MAR 5.5.3

How to check it without Arxo's tools

1. Open Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 January 2026) and find MAR V13, 5.5.3(c) (rule), page 54; MAR V13, 5.5.3(d) and the closing words of the lead-in (rule), page 54; MAR V13, 5.5.2 (rule), page 53. Compare the text with the quotation above. A copy is kept in this register: 163c0ad176174003-mar_v13_01.01.2026.pdf (SHA-256 163c0ad17617400321bc039bc3f91829586cbde62fec9a8d37e946d417252e7d, 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

• Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 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-2026-0097, https://arxo.io/findings/ARXO-2026-0097/ (status as of 2026-10-24). Data: ARXO-2026-0097.json.