Fallback signatories of prudential returns: 'Risk Manager' is called a Controlled Function, but in GEN it is a Designated Function

BBR 3.7(2) requires, if the primary signatories are unavailable, signature by 'both of the individuals approved to exercise the following Controlled Functions: (a) the Risk Manager function; (b) the Compliance Officer function'. GEN 2.2.1 lists Controlled Functions as GEN 2.2.2-2.2.5 (SEO, Director, Finance Officer, Compliance Officer); Risk Manager is GEN 2.3.5 and may be held by a Designated Individual who is not AFSA-approved (GEN 2.1.2(2)). In GEN at the BBR's adoption (2018) there was no Risk Manager function at all.

Proposed correction

Please either refer in 3.7(2) to "the individuals performing the Risk Manager function (GEN 2.3.5) and the Compliance Officer function", or make the Risk Manager a Controlled Function in GEN.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Banking Business Prudential Rules (BBR), V6

Place

BBR 3.7(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.

be signed by both of the individuals approved to exercise the following Controlled Functions:

the Risk Manager function;

The functions specified in GEN 2.2.2 to 2.2.5 are Controlled Functions.

The Risk Manager function is carried out by an individual who is a Director, Partner or

How to check it without Arxo's tools

1. Open AIFC Banking Prudential Rules_V6 (with amendments as of 13 April 2025, which commence on 13 October 2025) and find BBR 3.7(2); BBR 3.7(2)(a). Compare the text with the quotation above. A copy is kept in this register: 6384caa7b1938818-bbr_v6_13.10.2025_ma.pdf (SHA-256 6384caa7b19388180b780ec19044e1261cae3021c63c670f14ceb35285107022, copy of the official file).
2. Open AIFC General Rules (GEN), V20 and find GEN V20 2.2.1; GEN V20 2.3.5. Compare the text with the quotation above. A copy is kept in this register: e863a30c73072b03-gen-v20.pdf (SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681, copy of the official file).
3. 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

• AIFC Banking Prudential Rules_V6 (with amendments as of 13 April 2025, which commence on 13 October 2025)
• AIFC General Rules (GEN), V20

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-2026-0129, https://arxo.io/findings/ARXO-2026-0129/ (status as of 2026-10-24). Data: ARXO-2026-0129.json.