Arxo Findings Register · Arxo Law

ARXO-2026-0169 · Reported

Bank-cooperation Rules: Schedule 2 still shows the 2023 DAA capital table (Self-managed Fund row, old DATF measure), while 3.3.1 refers to the DAA rules

Rule 3.3.1 of the Rules and mechanisms of cooperation with second-tier banks requires Digital Asset Service Providers to hold minimum capital "in accordance with rules 2.2. and 3.2" of the DAA, and 3.3.2 says the amounts "are specified in Schedule 2". Schedule 2, both in the PDF on aifc.kz (approved 11 December 2023) and on the regulator's website, still has (1) the row "Managing a Collective Investment Scheme, which is a Self-managed Fund ..." with USD 200,000, which the DAA no longer contains (it is absent from the consolidated version in force from 1 January 2025), and (2) the old measure for operating a Digital Asset Trading Facility: "sufficient working capital ... in different market conditions (both negative and positive scenarios)". Since 1 January 2026 the DAA uses "operational expenses in fiat currency". The other rows match. It is not clear which source governs.

Proposed correction

Please confirm whether Schedule 2 is meant to set its own amounts or only to reproduce the DAA, and then update Schedule 2 to the current DAA tables or replace it with a reference to DAA 2.2 and 3.2.

Jurisdiction
Kazakhstan — AIFC
Act
Rules and mechanisms of cooperation of unbacked digital asset exchanges and Centre Participants with second-tier banks of the Republic of Kazakhstan
Place
Cooperation Rules 3.3.2
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.

The amounts of minimum capital of Digital Asset Service Providers are specified in Schedule
Normative text · Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka · Cooperation Rules 3.3.2 · retrieved 2026-10-23 · SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0 · copy
Digital Asset Service Providers are required to provide a minimum amount of capital in accordance with rules 2.2. and 3.2 of the of the AIFC Rules On Digital Asset Activities
Normative text · Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka · Cooperation Rules 3.3.1 · retrieved 2026-10-23 · SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0 · copy
equal to sufficient working capital in fiat
Normative text · Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka · Cooperation Rules Schedule 2, DATF row (rendered page checked) · retrieved 2026-10-23 · SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0 · copy
which is a Self-managed Fund and has an
Normative text · Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka · Cooperation Rules Schedule 2, Self-managed Fund row · retrieved 2026-10-23 · SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0 · copy
equal to operational expenses in fiat currency
Normative text · AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) · DAA V5 Table 1, DATF row (rendered page checked) · retrieved 2026-10-23 · SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557 · copy
which is a Self-managed Fund and has an
Prior edition · AIFC Rules on Digital Asset Activities Initial Version · DAA initial version Table 2 - the row Schedule 2 copies · retrieved 2026-10-23 · SHA-256 b2e861a30dc0572cad84b883e338a785dd3bc1239d668642df59d25fa86e7c0c · copy
The amounts of minimum capital of Digital Asset Service Providers are specified in Schedule 2 to these Rules.
Official publication · https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan · Regulator's website (orderly.myafsa.com), Cooperation Rules 3.3.2 · retrieved 2026-10-23 · SHA-256 b0b62a22bf8c5cfe4282768d0211035dea0d51e570bd610930c2439070cd2dae · copy
which is a Self-managed Fund and has an appointed Eligible Custodian
Official publication · https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan · Regulator's website, Cooperation Rules Schedule 2, Self-managed Fund row · retrieved 2026-10-23 · SHA-256 b0b62a22bf8c5cfe4282768d0211035dea0d51e570bd610930c2439070cd2dae · copy
an amount equal to sufficient working capital in fiat currency to continue business for a period of 12 months, based on realistic forecasts for the business in different market conditions (both negative and positive scenarios)
Official publication · https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan · Regulator's website, Cooperation Rules Schedule 2, DATF row · retrieved 2026-10-23 · SHA-256 b0b62a22bf8c5cfe4282768d0211035dea0d51e570bd610930c2439070cd2dae · copy

How to check it without Arxo's tools

  1. Open Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka and find Cooperation Rules 3.3.2; Cooperation Rules 3.3.1; Cooperation Rules Schedule 2, DATF row (rendered page checked); Cooperation Rules Schedule 2, Self-managed Fund row. Compare the text with the quotation above. A copy is kept in this register: fdae78fa000df953-rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan.pdf (SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0, copy of the official file).
  2. 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 Table 1, DATF row (rendered page checked). 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).
  3. Open AIFC Rules on Digital Asset Activities Initial Version and find DAA initial version Table 2 - the row Schedule 2 copies. 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).
  4. Open https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan and find Regulator's website (orderly.myafsa.com), Cooperation Rules 3.3.2; Regulator's website, Cooperation Rules Schedule 2, Self-managed Fund row; Regulator's website, Cooperation Rules Schedule 2, DATF row. Compare the text with the quotation above. A copy is kept in this register: b0b62a22bf8c5cfe-orderly-coop.html (SHA-256 b0b62a22bf8c5cfe4282768d0211035dea0d51e570bd610930c2439070cd2dae, copy of the official file).
  5. 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

Reported to

DateInstitutionChannelReference
2026-10-27Astana Financial Services Authority (AFSA)e-mail

Responses

No response recorded.

Documents and reproduction

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-2026-0169, https://arxo.io/findings/ARXO-2026-0169/ (status as of 2026-10-24). Data: ARXO-2026-0169.json.