MAR Schedule 4 para 4(a)(iii) points to 'technology and governance requirements set out in AMI 2-1.2'; those are in AMI 2-1.1

MAR Schedule 4 para 4(a)(iii) requires a Security Token prospectus to explain 'how the operator of the facility meets the technology and governance requirements set out in AMI 2-1.2'. In AMI V11 the technology and governance requirements are AMI 2-1.1 ('Technology and governance requirements'); AMI 2-1.2 is 'Operating a facility for Investment Tokens that permits direct access'. The same mismatch existed when Schedule 4 was introduced (AMI V8, 1 Jan 2024).

Proposed correction

Please replace "AMI 2-1.2" with "AMI 2-1.1" in MAR Schedule 4, paragraph 4(a)(iii). The words "technology and governance requirements" already fix the meaning, so this is an editorial correction under section 19(3)(a) of the AIFC Regulations on AIFC Acts.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Market Rules (MAR), V13

Place

MAR V13, Schedule 4 para 4(a)(iii) (rule), page 122

Record

Discrepancy

Class

Amendments

Where it arose

The amending 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.

requirements set out in AMI 2-1.2;

Technology and governance requirements

Operating a facility for Investment Tokens that permits direct access

requirements set out in AMI 2-1.2;

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, Schedule 4 para 4(a)(iii) (rule), page 122. 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. Open Authorised Market Institution Rules V11., (with amendments as of 7 December 2025, which commence on 1 January 2026) and find AMI V11, 2-1.1 heading, page 23; AMI V11, 2-1.2 heading, page 24. Compare the text with the quotation above. A copy is kept in this register: 8f6c60e7a2ea9f1b-ami_v11_01.01.2026-1.pdf (SHA-256 8f6c60e7a2ea9f1b70a5fc63cf33f8f9f4e5192e4f54dec80e109c914651b198, copy of the official file).
3. Open Market Rules A9., with amendments as of 9 December, commence on 1 August 2023 and find MAR Amendments No. 9 (STO, in force 1 Jan 2024), Schedule 4 para 4(a)(iii). Compare the text with the quotation above. A copy is kept in this register: 45c2f66a50e2526f-mar_a9_01.01.2023-sto.pdf (SHA-256 45c2f66a50e2526f20d3a04827c87229a57cb81cbe1ddc9df647aceafc76c78d, copy of the official file).
4. 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)
• Authorised Market Institution Rules V11., (with amendments as of 7 December 2025, which commence on 1 January 2026)
• Market Rules A9., with amendments as of 9 December, commence on 1 August 2023

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-2026-0099, https://arxo.io/findings/ARXO-2026-0099/ (status as of 2026-10-24). Data: ARXO-2026-0099.json.