AML 13.6.1(b), 13.8.1, 13.8.2, 14.1.1(d)–(e), 14.5.1(c): references to "AML 13.7.3" now point to the wrong rule

Seven references to "a notification to the MLRO under AML 13.7.3" survive from the 2018 numbering. AML 13.7.3 is now "Suspicious Activity and Transactions Controls" and creates no notification; the employee's duty to report to the MLRO is AML 13.7.5. The MLRO's duties to enquire, to decide on a suspicious transaction report, to record reasons and to keep records are attached to the old number.

Proposed correction

Please update the seven references to AML 13.7.3 that are meant to identify employee notifications to AML 13.7.5 (an editorial correction under section 19(3)(a) of the AIFC Regulations on AIFC Acts).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML)

Place

AML 13.6.1(b)

Record

Discrepancy

Class

Amendments

Where it arose

The amending act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-23

Evidence

Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.

acting as the point of contact to receive notifications from the Relevant Person’s employees under AML 13.7.3.;

A Relevant Person must ensure that where the Relevant Person's MLRO receives a notification under AML 13.7.3., the MLRO, without delay:

enquires into and documents the circumstances in relation to which the notification made under AML 13.7.3. was made;

Where, following a notification to the MLRO under AML 13.7.3, no STR is made, a Relevant Person must record the reasons for not making a STR.

understand its arrangements regarding the making of a notification to the MLRO under AML 13.7.3.;

notifications made under AML 13.7.3.;

Suspicious Activity and Transactions Controls

A Relevant Person must register in the FIU reporting system for submitting STRs or TTRs before the commencement of its business activities.

that a person is engaged in or attempting money laundering, that employeepromptly notifies the Relevant Person’s MLRO and provides the MLRO with all relevant information within the employee's knowledge.

How to check it without Arxo's tools

1. Open AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML), as of 15 December 2024 and find AML 13.6.1(b) (Oversight responsibility of MLRO); AML 13.8.1 lead-in (Activity upon notification); AML 13.8.1(a); AML 13.8.2 (Recording reasons for not making a STR); AML 14.1.1(e) (Training); 14.1.1(d) has the same reference; AML 14.5.1(c) (Obligation to keep records); AML 13.7.3 heading (number visible on page image only); AML 13.7.3 second paragraph — no notification to the MLRO in this rule; AML 13.7.5 (Employee reporting to MLRO) — the actual notification duty. Compare the text with the quotation above. A copy is kept in this register: 6ca352e46b7bd314-aml.pdf (SHA-256 6ca352e46b7bd314846207558a7131c1525cb9ad14aa6a9ba9d6cd2d2edd35b1, 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.

History

1. 2026-10-23Confirmed 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-2026-0029, https://arxo.io/findings/ARXO-2026-0029/ (status as of 2026-10-23). Data: ARXO-2026-0029.json.