Glossary: three insurance client money terms point to COB 11.8, which no longer exists

"Client Money Distribution Rules" ("COB 11.8.14"), "Client Money" ("COB 11.8.4") and "Segregated Client" ("COB 11.8") point to COB 11.8. Chapter 11 of the current COB ends at 11.7; the client money rules for insurance intermediation are in COB 8.5 (including 8.5.5, money held as agent of an insurer, and 8.5.15, distribution rules). The draft in Consultation Paper AFSA-PSRD-CSP-2026-0005 changes the fourth such entry, "Insurance Intermediary Audit Report", to refer to GEN 6.3.9, which we support, but leaves these three as they are.

Proposed correction

Please reconcile the three definitions with COB 8.5.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Glossary (GLO), V23

Place

Glossary V23, entry "Client Money Distribution Rules"

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

2026-10-25

Evidence

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

In COB 11, the Rules contained in COB 11.8.14.

in accordance with COB 11.8.4;

COB 8.2, COB 8.3 or COB 11.8.

The report specified in COB 11.8.15 GEN 6.3.9.

How to check it without Arxo's tools

1. Open AIFC Glossary (GLO), V23 and find Glossary V23, entry "Client Money Distribution Rules"; Glossary V23, entry "Client Money"; Glossary V23, entry "Segregated Client". 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).
2. Open AFSA Consultation Paper AFSA-PSRD-CSP-2026-0005: Targeted Amendments to the AIFC Rules (15.07.2026) and find Consultation Paper AFSA-PSRD-CSP-2026-0005 (15.07.2026, closed, not adopted as of 25.10.2026), Annex, Glossary «Insurance Intermediary Audit Report». Compare the text with the quotation above. A copy is kept in this register: 05a2ed115abcc1ab-AFSA-PSRD-CSP-2026-0005.pdf (SHA-256 05a2ed115abcc1ab90a39c74ced2414b5a157d49522442ec652e29947cb34872, 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-2026-0067, https://arxo.io/findings/ARXO-2026-0067/ (status as of 2026-10-25). Data: ARXO-2026-0067.json.