AUD Annex C (Insurance Intermediary Auditor's Report) measures client money 'in accordance with COB 11', which has no client-money rules

AUD Annex C (Insurance Intermediary Auditor's Report), paragraphs (a) and (b)(i), measure client money "in accordance with COB 11", while (b)(iii)-(iv) refer to COB 8. The client-money rules for insurance intermediaries were added to COB as section 8.5 in December 2018; COB 11 now ends at 11.7.7 and contains no client-money rules. The meaning can be recovered from (b)(iii)-(iv) and the title of the Annex.

Proposed correction

Please replace "COB 11" with "COB 8.5" in Annex C (an editorial correction under section 19(3)(a) of the AIFC Regulations on AIFC Acts).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Auditor Rules

Place

AUD Annex C(a)

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.

the amount of Client Money the Insurance Intermediary was holding and controlling in accordance with COB 11

any of the requirements in COB 8 have not been met;

AMENDMENTS No. 2.1

Client money: Insurance Intermediation and Insurance Management

How to check it without Arxo's tools

1. Open AIFC Auditor Rules and find AUD Annex C(a); AUD Annex C(b)(iii). Compare the text with the quotation above. A copy is kept in this register: b7eb7eed75dfea7f-aifc-auditor-rules.pdf (SHA-256 b7eb7eed75dfea7f0aefc2937b881836c3b1a7ba4f59701ec90fcfec5af4fae3, copy of the official file).
2. Open Conduct Of Business Rules A2., with amendments as of 2 December 2018, commence on 2 December 2018 and find COB Amendments No. 2.1 (approved 2 December 2018), cover; COB Amendments No. 2.1, new section 8.5 heading. Compare the text with the quotation above. A copy is kept in this register: e9854ad17038b657-cob_a2_02.12.2018.pdf (SHA-256 e9854ad17038b6576e3910da0808eb63798044691da4aeab0752173116b85839, 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 Auditor Rules
• Conduct Of Business Rules A2., with amendments as of 2 December 2018, commence on 2 December 2018

Related records

• ARXO-2026-0166 — AUD 9.2.1 table: the rows for Non-Exempt Funds and Reporting Entities refer to CIR 11.4(a) and MAR 3.2.2, which do not require an audit

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-2026-0167, https://arxo.io/findings/ARXO-2026-0167/ (status as of 2026-10-24). Data: ARXO-2026-0167.json.