Arxo Findings Register · Arxo Law

ARXO-2026-0091 · Reported

COB 8.5.13(2) and the 16.2 table use the undefined 'Insurance Bank Account'

COB 8.5 requires Client Money to be held in "Client Money Accounts" (8.5.6, 8.5.9). COB 8.5.13(2) requires records of "all sums withdrawn from the Insurance Bank Account as a result of credit taken under COB 8.5.12", and the table in COB 16.2 repeats it. "Insurance Bank Account" is not defined in COB or in the Glossary and is used nowhere else. The term has been in COB since the first version (then COB 11.8.12). The meaning (the Client Money Account) can be recovered from 8.5.9 and 8.5.12.

Proposed correction

Please replace "Insurance Bank Account" with "Client Money Account" in COB 8.5.13(2) and in the table in COB 16.2.

Jurisdiction
Kazakhstan — AIFC
Act
AIFC Conduct of Business Rules (COB), V17
Place
COB 8.5.13(2)
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.

withdrawn from the Insurance Bank Account as a result of credit taken under COB 8.5.12
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.5.13(2) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · copy
ensure that Client Money is held in one or more Client Money Accounts with one or more
Normative text · Conduct of Business Rules_V17 (with amendments as of 7 December 2025, which commence on 13 January 2026) · COB 8.5.9(a) · retrieved 2026-10-23 · SHA-256 ae99fece8c92521046670bbcf56bf4176715e22ece4779e4ba8b461a631793c6 · 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 8.5.13(2); COB 8.5.9(a). 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

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-2026-0091, https://arxo.io/findings/ARXO-2026-0091/ (status as of 2026-10-24). Data: ARXO-2026-0091.json.