ARXO-2026-0031 · Reported
AML 14.2.3(b) refers to the staff training rule AML 14.1.1(b)
AML 14.2.3 deals with Group entities, but (b) requires the firm to document "the basis for its satisfaction that the requirement in AML 14.1.1.(b) is met" — the rule on training the firm's own employees. The intended target is probably AML 14.2.1(b) or the equivalence test in AML 14.2.2.
Proposed correction
Please confirm which requirement AML 14.2.3(b) is meant to refer to (group application, equivalence or additional measures) and correct the reference.
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML)
- Place
- AML 14.2.3(b)
- 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
- 2026-10-23
Evidence
Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.
document the basis for its satisfaction that the requirement in AML 14.1.1.(b) is met.are regularly given training in how to recognise and deal with transactions and other activities which may be related to money laundering;The requirement in AML 14.2.1. does not apply if the Relevant Person can satisfy the AFSA that the relevant branch, Subsidiary or Group entity is subject to regulation
How to check it without Arxo's tools
- Open AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML), as of 15 December 2024 and find AML 14.2.3(b); AML 14.1.1(b) — the target as written; AML 14.2.2 — the satisfaction test for Group entities. 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). - 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
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-27 | Astana Financial Services Authority (AFSA) |
Responses
No response recorded.
History
- 2026-10-23Confirmed by Arxo
- 2026-10-27Entered in the register
- 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0031, https://arxo.io/findings/ARXO-2026-0031/ (status as of 2026-10-23). Data: ARXO-2026-0031.json.