ARXO-2026-0101 · Reported
'Environmental Instrument Tokens' (AMI 2.6.1(3)) is undefined; the Glossary instead has a second 'Commodity Derivative Token' entry in the E-position
AMI 2.6.1(3) requires a direct-access Member whose access is only for "Commodity Derivative Tokens or Environmental Instrument Tokens" to be a Professional Client. "Environmental Instrument Token" is not defined in the Glossary. Glossary V23 has two entries "Commodity Derivative Token" with the same text: one in alphabetical place under C, and a second one directly after "Environmental Instrument". The AFSA online Glossary has the same duplicate. The second entry may have been meant to define "Environmental Instrument Token"; the text does not show this.
Proposed correction
Please define "Environmental Instrument Token" in the Glossary (for example by relabelling the second "Commodity Derivative Token" entry, with wording set by the AFSA) and remove the duplicate entry.
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Authorised Market Institution Rules (AMI), V11
- Place
- AMI V11, 2.6.1(3) (rule), page 14
- Record
- Discrepancy
- Class
- Text of the act
- Where it arose
- Not established
- 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.
Commodity Derivative Tokens or Environmental Instrument Tokens, is a ProfessionalA digital representation of a Commodity Derivative, that is issued, transferred and stored using DLT or other similar technology approved by the AFSA.
How to check it without Arxo's tools
- Open Authorised Market Institution Rules V11., (with amendments as of 7 December 2025, which commence on 1 January 2026) and find AMI V11, 2.6.1(3) (rule), page 14. Compare the text with the quotation above. A copy is kept in this register: 8f6c60e7a2ea9f1b-ami_v11_01.01.2026-1.pdf (SHA-256
8f6c60e7a2ea9f1b70a5fc63cf33f8f9f4e5192e4f54dec80e109c914651b198, copy of the official file). - Open AIFC Glossary (GLO), V23 and find Glossary V23, page 20 (second 'Commodity Derivative Token' entry, after 'Environmental Instrument'; rendered page checked). 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
- Authorised Market Institution Rules V11., (with amendments as of 7 December 2025, which commence on 1 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-2026-0101, https://arxo.io/findings/ARXO-2026-0101/ (status as of 2026-10-24). Data: ARXO-2026-0101.json.