COB 8.5 was extended to Insurance Managers but the distribution waterfall and agency rule still name only the Insurance Intermediary

Amendments No. 2 rewrote the old COB 11.8 as COB 8.5 for "an Insurance Intermediary or Insurance Manager", and that phrase runs through COB 8.5. Three places still name only the Insurance Intermediary: 8.5.15(2)(c) "where insufficient funds are held by the Insurance Intermediary"; 8.5.15(2)(d)(i) "trustee in bankruptcy over the Insurance Intermediary, payment must be made accordance with the AIFC Insolvency Regulations"; and 8.5.5(b) "once the money is received by the Insurance Intermediary". The Investment Business rule 8.2.16(2)(d)(i) covers "the Authorised Firm or the Nominee Company".

Proposed correction

Please add "or Insurance Manager" after "Insurance Intermediary" in COB 8.5.15(2)(c), 8.5.15(2)(d)(i) and 8.5.5(b), and read "made in accordance with" in 8.5.15(2)(d)(i).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Conduct of Business Rules (COB), V17

Place

COB 8.5.15(2)(d)(i)

Record

Discrepancy

Class

Amendments

Where it arose

The amending 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.

bankruptcy over the Insurance Intermediary, payment must be made accordance with the AIFC Insolvency Regulations; or

where insufficient funds are held by the Insurance

insurance cover is maintained for the Client once the money is received by the Insurance

COB 8.5 applies to an Insurance Intermediary or Insurance Manager that receives or holds

bankruptcy over the Insurance Intermediary, payment must be made

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 8.5.15(2)(d)(i); COB 8.5.15(2)(c); COB 8.5.5(b); COB 8.5.1. 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 A2., with amendments as of 2 December 2018, commence on 2 December 2018 and find Amendments No. 2, 8.5.15(2)(d)(i) as made. Compare the text with the quotation above. A copy is kept in this register: e9854ad17038b657-cob_a2_02.12.2018.pdf (SHA-256 e9854ad17038b6576e3910da0808eb63798044691da4aeab0752173116b85839, 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 A2., with amendments as of 2 December 2018, commence on 2 December 2018

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-2026-0086, https://arxo.io/findings/ARXO-2026-0086/ (status as of 2026-10-24). Data: ARXO-2026-0086.json.