Client asset rules give regulatory roles to 'the AIFC' (the Centre) where the regulator, the AFSA, is meant

The Glossary defines AIFC as the Astana International Financial Centre (a territory/regime). COB nevertheless says: firms must demonstrate grounds 'to the AIFC's satisfaction' (8.2.11, 8.3.8); Client Money may be paid out in circumstances 'otherwise authorised by the AIFC' (8.2.13(e)); disclosure of 'other Distribution Event stipulated by the AIFC' (8.2.18(a)(ii)). The parallel collateral disclosure (8.3.2(d)) says 'stipulated by the AFSA', and the Glossary Distribution Event (c) is a direction by the AFSA.

Proposed correction

Please replace "AIFC" with "AFSA" in COB 8.2.11, 8.2.18(a)(ii) and 8.3.8, and state in COB 8.2.13(e) whether "authorised by the AFSA" or "authorised under the AIFC Acts" is meant.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Conduct of Business Rules (COB), V17

Place

COB 8.2.11 last paragraph

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.

An Authorised Firm must be able to demonstrate to the AIFC's satisfaction the grounds upon

paid out in circumstances that are otherwise authorised by the AIFC.

Event stipulated by the AIFC

AFSA, any excess Collateral will be sold

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 8.2.11 last paragraph; COB 8.2.13(e); COB 8.2.18(a)(ii); COB 8.3.2(d). 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. 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)

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-2026-0090, https://arxo.io/findings/ARXO-2026-0090/ (status as of 2026-10-24). Data: ARXO-2026-0090.json.