ARXO-2026-0085 · Reported
COB 2.3.1(b) lists only COB 2.5.1 and 2.5.5 and omits Undertakings assessed under COB 2.5.6
COB 2.3.1(b) allows a Person to be classified as a Professional Client if it meets the requirements to be an Assessed Professional Client "in accordance with COB 2.5.1 or 2.5.5". COB 2.5.1 covers individuals and 2.5.5 joint account holders. COB 2.5.6 (Undertakings with own funds of at least USD 1 million) is not listed, although 2.5.6 itself applies "For the purposes of COB 2.3.1" and the Glossary defines Assessed Professional Client by "COB 2.5.1 and 2.5.6". The words of 2.5.6 and the Glossary keep the intended meaning, but the list in 2.3.1(b) does not match them.
Proposed correction
Please align the list in COB 2.3.1(b) with COB 2.5.6 and the Glossary definition, for example "COB 2.5.1, 2.5.5 or 2.5.6".
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Conduct of Business Rules (COB), V17
- Place
- COB 2.3.1(b)
- 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 2.5.1 or 2.5.5, provided that Person has not been classified as a Retail Client inFor the purposes of COB 2.3.1, an Authorised Firm may treat an Undertaking as an AssessedHas the meaning given in COB 2.5.1 and 2.5.6.
How to check it without Arxo's tools
- Open Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) and find COB 2.3.1(b); COB 2.5.6. 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). - Open AIFC Glossary (GLO), V23 and find Glossary V23, 'Assessed Professional 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). - 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.
Documents and reproduction
- Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026)
- AIFC Glossary (GLO), V23
History
- 2026-10-24Confirmed 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-2026-0085, https://arxo.io/findings/ARXO-2026-0085/ (status as of 2026-10-24). Data: ARXO-2026-0085.json.