DAA 3.9.1(2) and 3.8.4(2): permission to combine items '(f) and (j)' copied from COB Schedule 3 after relettering

In COB Schedule 3 (source text) (f) is the price and (j) the firm's charges, so combining them gives an all-in price. DAA 3.9.1 drops COB item (c) (client's name), so the price is (e) and the charges (i); yet 3.9.1(2) still says '(f) and (j)' - now the execution-only statement and amounts received from another Person, which cannot form a single price. DAA 3.8.4 drops three COB items (principal/agent, client name, total payable) and ends at (i): '(j)' does not exist there at all (and the paragraph is numbered (2) without a (1)).

Proposed correction

Please read "items (e) and (i)" for "items (f) and (j)" in 3.9.1(2) and "items (d) and (g)" in 3.8.4(2), and number the lead-in of 3.8.4 as (1).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, 3.9.1(e)

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.

(e) the price or unit price at which the Transaction was executed;

(f) if applicable, a statement that the Transaction was executed on an execution-only basis;

(j) the amount or basis of any amounts received from another Person in connection with the services.

A Digital Asset Service Provider may combine items (f) and (j) above in respect of a Transaction where the Client has requested a note showing a single price combining both of these items.

(i) a statement that the price at which the Transaction has been Executed is on a Historic Price or Forward Price basis, as the case may be.

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, 3.9.1(e); DAA V5, 3.9.1(f); DAA V5, 3.9.1(j); DAA V5, 3.8.4(2) and 3.9.1(2) (same sentence, pp.67 and 68); DAA V5, 3.8.4(i) - last item of the list. 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. 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 Rules on Digital Asset Activities_V5 (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-2026-0151, https://arxo.io/findings/ARXO-2026-0151/ (status as of 2026-10-24). Data: ARXO-2026-0151.json.