GEN Schedule 4, paragraph 5(5)(c): the investment crowdfunding delegation rule requires notice to "Borrowers or lenders"

Paragraph 5(5)(c) (Operating an Investment Crowdfunding Platform) repeats paragraph 4(5)(c) of the loan crowdfunding definition: the delegate must "notify Borrowers or lenders". Paragraph 5 otherwise speaks of Issuers and Investors; for shares and other non-debt investments there is no Borrower or lender to notify.

Proposed correction

Please use "Issuers or Investors, as applicable" in paragraph 5(5)(c).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC General Rules (GEN), V20

Place

Schedule 4 para 5(5)(c) / page 59 (identical words also in para 4(5)(c), page 58)

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.

require the other Person to notify Borrowers or lenders that they are appointed by and acting

providing information or performing other duties relating to Investments on behalf of the

facilitated via a Loan Crowdfunding Platform as set out in paragraph 4 of Schedule 4 of AIFC General Rules.

How to check it without Arxo's tools

1. Open AIFC General Rules (GEN), V20 and find Schedule 4 para 5(5)(c) / page 59 (identical words also in para 4(5)(c), page 58); Schedule 4 para 5(3)(a) / page 58. 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).
2. Open AIFC Glossary (GLO), V23 and find Glossary V23, entry "Borrower". Compare the text with the quotation above. A copy is kept in this register: 041617346ad87a9f-glo-v23.pdf (SHA-256 041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45, copy of the official file).
3. 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-2026-0061, https://arxo.io/findings/ARXO-2026-0061/ (status as of 2026-10-23). Data: ARXO-2026-0061.json.