Arxo Findings Register · Arxo Law

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 in
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 2.3.1(b) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
For the purposes of COB 2.3.1, an Authorised Firm may treat an Undertaking as an Assessed
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 2.5.6 · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
Has the meaning given in COB 2.5.1 and 2.5.6.
Normative text · AIFC Glossary (GLO), V23 · Glossary V23, 'Assessed Professional Client' · retrieved 2026-10-23 · SHA-256 041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45 · copy

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 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).
  2. 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).
  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

Reported to

DateInstitutionChannelReference
2026-10-27Astana Financial Services Authority (AFSA)e-mail

Responses

No response recorded.

Documents and reproduction

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-2026-0085, https://arxo.io/findings/ARXO-2026-0085/ (status as of 2026-10-24). Data: ARXO-2026-0085.json.