AML 2.2(d) and Annex 1 define "senior management" differently

AML 2.2(d) says that "In these Rules 'senior management' means" every member of executive management, including every member of the Governing Body. Annex 1, which AML 1.6 names as the place of definitions, defines it as "a high-level executive who oversees the operations and performance of one or more departments". Responsibility under 2.2(a) and approvals for politically exposed persons depend on which definition applies.

Proposed correction

Please reconcile the definitions of "senior management" in AML 2.2(d) and Annex 1, or say expressly where each applies.

Jurisdiction

Kazakhstan — AIFC

Act

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

Place

AML 2.2(d)

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

2026-10-23

Evidence

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

In these Rules “senior management” means:

for a AIFC entity, every member of the Relevant Person’s Governing Body;

a high-level executive who oversees the operations and performance of one or more departments within a company

Words and expressions specific to these Rules that require defining are set out in the Annex 1.

Responsibility for a Relevant Person's compliance with these Rules lies with every member of its senior management.

obtains the approval of senior management to commence a business relationship with the customer.

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 2.2(d); AML 2.2(d)(i); Annex 1, entry 'senior management'; AML 1.6 — Annex 1 holds the definitions; AML 2.2(a) — responsibility; AML 6.3.3(b) — PEP approval. 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-2026-0033, https://arxo.io/findings/ARXO-2026-0033/ (status as of 2026-10-23). Data: ARXO-2026-0033.json.