DAA 4.5(2): annual recovery/wind-down audit is attached to item (n), which became 'conflicts of interests'

DAA 4.5(2) requires an audit of "the policies and procedures required by DAA 4.5.1(n)". There is no rule 4.5.1; in 4.5(1) item (n) is now "conflicts of interests" and "recovery and winddown" is (o). In the version published as the initial version, (n) was "recovery and winddown". The letters changed in the consolidated version in force from 1 January 2025, and 4.5(2) was not updated. The subject of the audit ("the amount required to achieve recovery and orderly winddown") shows the intended item.

Proposed correction

Please read "DAA 4.5(1)(o)" for "DAA 4.5.1(n)" in 4.5(2) (an editorial correction under section 19(3)(a) of the AIFC Regulations on AIFC Acts).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, 4.5(2)

Record

Discrepancy

Class

Text of the act

Where it arose

Not established

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 policies and procedures required by DAA 4.5.1(n) must include an independent audit to be conducted by a third party at least annually

(n) conflicts of interests;

(o) recovery and winddown; and

(n) recovery and winddown; and

(o) recovery and winddown; and

How to check it without Arxo's tools

1. Open AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) and find DAA V5, 4.5(2); DAA V5, 4.5(1)(n); DAA V5, 4.5(1)(o). Compare the text with the quotation above. A copy is kept in this register: 4a5174f747a66c22-daa_v5_01.01.2026.pdf (SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557, copy of the official file).
2. Open AIFC Rules on Digital Asset Activities Initial Version and find DAA initial version, 4.5(1)(n). Compare the text with the quotation above. A copy is kept in this register: b2e861a30dc0572c-aifc-rules-on-digital-asset-activities-daa_stablecoins.pdf (SHA-256 b2e861a30dc0572cad84b883e338a785dd3bc1239d668642df59d25fa86e7c0c, copy of the official file).
3. Open AIFC Rules on Digital Asset Activities V3., with amendments as of 15 December 2024, commence on 1 January 2025 and find DAA V3 (file v2, 01.01.2025), 4.5(1)(o). Compare the text with the quotation above. A copy is kept in this register: 35da4b9447d4c14d-aifc-rules-on-digital-asset-activities-daa_v2_01.01.2025_gk_zs-1-1.pdf (SHA-256 35da4b9447d4c14d59fb6c46151ec2d00b579e12494a40501c0be529c9ee6477, 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
• AIFC Authority — body that prepares AIFC acts and publishes them on the AIFC website

Reported to

Responses

No response recorded.

Documents and reproduction

• AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026)
• AIFC Rules on Digital Asset Activities Initial Version
• AIFC Rules on Digital Asset Activities V3., with amendments as of 15 December 2024, commence on 1 January 2025

Related records

• ARXO-2026-0159 — aifc.kz DAA page: the "V2 (18 October 2024)" link opens the initial version; the consolidated V4 is listed under "Amendments" and Amendments No. 3 under "Past Version"

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)
4. 2026-10-27Reported to AIFC Authority (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0150, https://arxo.io/findings/ARXO-2026-0150/ (status as of 2026-10-24). Data: ARXO-2026-0150.json.