ARXO-2026-0034 · Reported

AML Guidance after 13.1.3 cites GEN 2.1.2 for the MLRO appointment; it is now GEN 2.1.1(1)(d)

The Guidance says "Under GEN 2.1.2., the MLRO function is a mandatory appointment." In the current General Rules GEN 2.1.2(1) is omitted and the MLRO appointment is GEN 2.1.1(1)(d).

Proposed correction

Replace "GEN 2.1.2." with "GEN 2.1.1(1)(d)" (subject to the exemption for Credit Rating Agencies in GEN 2.1.1(3)); 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: Guidance on appointment of MLRO (a), after AML 13.1.3
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.

Under GEN 2.1.2., the MLRO function is a mandatory appointment.

Normative text · AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AML), as of 15 December 2024 · Guidance on appointment of MLRO (a), after AML 13.1.3 · retrieved 2026-10-23 · SHA-256 6ca352e46b7bd314846207558a7131c1525cb9ad14aa6a9ba9d6cd2d2edd35b1 · copy

Subject to (2) an Authorised Person must make the following appointments and ensure that they are held by one or more Approved Individuals at all times:

Normative text · AIFC General Rules (GEN), V20 · GEN V20 2.1.1(1) · retrieved 2026-10-23 · SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681 · copy

Money Laundering Reporting Officer; and

Prior edition · AIFC General Rules, initial release · GEN initial release 2.1.2(a) · retrieved 2026-10-23 · SHA-256 acbe7b35cf6517f54bac1bec8e1904fd1feb21cf68e5f6705bef08699cd6a793 · copy

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 Guidance on appointment of MLRO (a), after AML 13.1.3. 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).
Open AIFC General Rules (GEN), V20 and find GEN V20 2.1.1(1). Compare the text with the quotation above. A copy is kept in this register: e863a30c73072b03-gen-v20.pdf (SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681, copy of the official file).
Open AIFC General Rules, initial release and find GEN initial release 2.1.2(a). Compare the text with the quotation above. A copy is kept in this register: acbe7b35cf6517f5-gen-initial.pdf (SHA-256 acbe7b35cf6517f54bac1bec8e1904fd1feb21cf68e5f6705bef08699cd6a793, 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)	e-mail

Date

Institution

Channel

Reference

2026-10-27

Astana Financial Services Authority (AFSA)

e-mail

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-2026-0034, https://arxo.io/findings/ARXO-2026-0034/ (status as of 2026-10-23). Data: ARXO-2026-0034.json.