AML Guidance refers to Chapter 6 for risk assessments; they are in Chapters 4 and 5

Guidance (k) after AML 4.3.3 and Guidance (j) after AML 6.3.4 refer to the customer risk assessment "under Chapter 6", and the sanctions Guidance (g) to "the risk assessments under Chapters 5 and 6". AML 1.5(d) places the customer risk assessment in Chapter 5; Chapter 6 contains none.

Proposed correction

Please align the risk-assessment references in the Guidance with the business and customer risk assessment provisions (Chapters 4 and 5).

Jurisdiction

Kazakhstan — AIFC

Act

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

Place

Guidance on RBA (k), after AML 4.3.3

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.

will also feed into the Relevant Person’s risk assessment of its customers (see Chapter 6).

money laundering risks identified under Chapter 6.

taking into account the risk assessments under Chapters 5 and 6.

Chapter 5 explains the concept of Customer Risk Assessments (“CRA”).

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 Guidance on RBA (k), after AML 4.3.3; Guidance on conducting CDD (j), after AML 6.3.4; Guidance on Government, Regulatory and International Findings (g); AML 1.5(d). 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-2026-0035, https://arxo.io/findings/ARXO-2026-0035/ (status as of 2026-10-23). Data: ARXO-2026-0035.json.