COB 1.2.4 lists 'COB 15 (Record Keeping)' for Trust Service Providers: COB 15 is complaints, record keeping is COB 16

COB 1.2.4 disapplies COB to Trust Service Providers except, among others, "COB 15 (Record Keeping)". Chapter 15 is "Complaints Handling and Dispute Resolution"; Chapter 16 is "Record Keeping and Internal Audit"; and section 15.4 inside Chapter 15 is "Record keeping" for complaints. The number and the label point to different provisions. The mismatch exists from the first version of COB (2017) and was kept through every later change to 1.2.4. Other exclusion rules name the chapters correctly, for example 1.2.2(g): "COB 15 (Complaints Handling and Dispute Resolution), COB 16 (Record Keeping and Internal Audit)".

Proposed correction

Please state which rules apply to Trust Service Providers: (1) COB 15 (Complaints Handling and Dispute Resolution); (2) COB 16 (Record Keeping and Internal Audit); (3) both; or (4) COB 15.4 (Record keeping), the complaint-records section of COB 15.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Conduct of Business Rules (COB), V17

Place

COB 1.2.4

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

2026-10-24

Evidence

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

COB 12 (Trust Service Providers), and COB 15 (Record Keeping).

COB 15 (Complaints Handling and Dispute Resolution), COB 16 (Record Keeping and Internal Audit)

COB 12 (Trust Service Providers), and COB 15 (Record Keeping).

An Authorised Firm must maintain a record of all Complaints made against it for a minimum

How to check it without Arxo's tools

1. Open Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) and find COB 1.2.4; COB 1.2.2(g); COB V17 15.4.1 (section 15.4 'Record keeping'). Compare the text with the quotation above. A copy is kept in this register: ae99fece8c925210-cob_v17_13.01.2026-1.pdf (SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6, copy of the official file).
2. Open Conduct Of Business Rules Initial version and find COB 1.2.4 in the initial version. Compare the text with the quotation above. A copy is kept in this register: f0613d3937d23587-cob_v1_fr0005_10.12.2017.pdf (SHA-256 f0613d3937d235871f74a92c9ccc430cfab72b4aba2873560ebdd390b6106e7f, 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.

Documents and reproduction

• Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026)
• Conduct Of Business Rules Initial version

History

1. 2026-10-24Confirmed 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-2026-0084, https://arxo.io/findings/ARXO-2026-0084/ (status as of 2026-10-24). Data: ARXO-2026-0084.json.