PMS 4.3 and 7.3(3) list different cases in which a redemption fee may be charged: may a fee be charged for a redemption during the agreement?

Two rules govern fees on the redemption of Electronic Money, and both use "only where". PMS 4.3(1) allows a fee where (a) the redemption is requested before the termination of the client agreement, (b) a fixed-term agreement is terminated early, or (c) redemption is requested more than one year after termination. PMS 7.3(3) allows a fee only where it "relates to early termination or late redemption". A redemption requested at early termination meets both rules. A redemption during a running agreement, without termination, is allowed by 4.3(1)(a) and referred to in 4.4(1), but does not fit 7.3(3). Read together, such a fee is not allowed, which leaves little room for 4.3(1)(a).

Proposed correction

Please clarify whether a fee may be charged for a redemption, including a partial redemption, during a running agreement, and align rules 4.3 and 7.3(3).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Providing Money Services (PMS)

Place

PMS 4.3(1) lead-in

Record

Question of reading or data

Class

Question of reading or data

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.

Redemption may be subject to a fee only where the fee is stated in the contract by PMS 4.2. (a) and:

the redemption is requested before the termination of the client agreement;

A Money Service Provider may impose a charge or fee for an Electronic Money redemption only where the relevant charge or fee:

relates to early termination or late redemption (that is, a redemption occurring more than 1 (one) year after the termination of the client agreement).

the Money Service Provider that issues Electronic Money must redeem the amount so requested subject to any fee imposed in accordance with PMS 4.3.

How to check it without Arxo's tools

1. Open AIFC Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026) and find PMS 4.3(1) lead-in; PMS 4.3(1)(a); PMS 7.3(3) lead-in; PMS 7.3(3)(b); PMS 4.4(1), p.16. Compare the text with the quotation above. A copy is kept in this register: 333935eb310b57bc-pms-rulebook-25.05.2025_-v.1.pdf (SHA-256 333935eb310b57bcba51ab477b3e11e65a88e7ccf094eda06bc4e023e4fdac1a, 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 Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 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-2026-0160, https://arxo.io/findings/ARXO-2026-0160/ (status as of 2026-10-24). Data: ARXO-2026-0160.json.