ARXO-2026-0062 · Reported
GEN 2.2.1 and 2.3.1: the ranges of Controlled and Designated Functions are out of date
GEN 2.2.1 says "The functions specified in GEN 2.2.2 to 2.2.5 are Controlled Functions", but the MLRO function is now GEN 2.2.5-1. GEN 2.3.1 says "The functions specified in GEN 2.3.2 to 2.3.4 are Designated Functions", but 2.3.4 is omitted and the Risk Manager and Internal Audit Manager functions are 2.3.5 and 2.3.6.
Proposed correction
"GEN 2.2.2 to 2.2.5-1" in GEN 2.2.1 and "GEN 2.3.2 to 2.3.6" in GEN 2.3.1 (editorial corrections under section 19(3)(a) of the AIFC Regulations on AIFC Acts).
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC General Rules (GEN), V20
- Place
- GEN 2.2.1 / page 15
- Record
- Discrepancy
- Class
- Amendments
- Where it arose
- The amending act
- Arxo's conclusion
- Confirmed
- Official text
- Unchanged at last check
- Last checked
- 2026-10-25
Evidence
Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.
The functions specified in GEN 2.2.2 to 2.2.5 are Controlled Functions.(d) Money Laundering Reporting Officer.2.2.5-1 Money Laundering Reporting OfficerThe functions specified in GEN 2.3.2 to 2.3.4 are Designated Functions.2.3.4. [intentionally omitted]The Risk Manager function is carried out by an individual who is a Director, Partner orThe Internal Audit Manager function is carried out by an individual who is a Director, Partner orAny of the functions specified in GEN 2.3.
How to check it without Arxo's tools
- Open AIFC General Rules (GEN), V20 and find GEN 2.2.1 / page 15; GEN 2.1.1(1)(d) / page 15; GEN 2.2.5-1 / page 16; GEN 2.3.1 / page 17; GEN 2.3.4 / page 18; GEN 2.3.5 / page 18; GEN 2.3.6 / page 18. 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 Glossary (GLO), V23 and find Glossary V23, entry "Designated Functions". 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). - 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-2026-0062, https://arxo.io/findings/ARXO-2026-0062/ (status as of 2026-10-25). Data: ARXO-2026-0062.json.