Arxo Findings Register · Arxo Law

ARXO-2026-0116 · Reported

AFSA online CIS misses other Amendments No. 7 changes: Venture Capital Fund (2.4(b)(iii)), 7.6(b) "Associates", and rule 1.6 without text

The AFSA online CIS includes many changes made by Amendments No. 7 (in force 1 January 2025), but not these: (1) 2.4(b)(iii) still describes a Venture Capital Fund as "an Exempt Fund and a Domestic Fund" that invests "in the equity share capital" of unlisted businesses; Amendments No. 7 deleted "and a Domestic Fund" and replaced "equity share capital" with "Securities and Units", while the online text already shows the feeder route added by the same amendment; (2) 7.6(b) still says "Associates" where Amendments No. 7 put "Related Parties"; (3) rule 1.6 (when a Fund invests in Digital Assets indirectly), inserted by Amendments No. 7, has a heading but no text under it.

Proposed correction

Please apply Amendments No. 7 to rules 2.4(b)(iii), 7.6(b) and 1.6 in the online CIS.

Jurisdiction
Kazakhstan — AIFC
Act
AIFC Collective Investment Scheme Rules (CIS), V8
Place
CIS V8 2.4(b)(iii)
Record
Discrepancy
Class
Publication and consolidation
Where it arose
The official publication
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.

a Venture Capital Fund, which is an Exempt Fund that:
Normative text · Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 · CIS V8 2.4(b)(iii) · retrieved 2026-10-23 · SHA-256 733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7 · copy
primarily invests in the Securities and Units of unlisted businesses which are at an early stage of development, either:
Normative text · Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 · CIS V8 2.4(b)(iii)(A) · retrieved 2026-10-23 · SHA-256 733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7 · copy
a Venture Capital Fund, which is an Exempt Fund and a Domestic Fund that:
Amending act · Collective Investment Scheme Rules A7., with amendments as of 15 December 2024, commence on 1 January 2025 · Amendments No. 7, page 3 (deletions rendered) · retrieved 2026-10-23 · SHA-256 26b1d661daa1376ede349c4366d802d11b0d58158c0ec1fcbf4da71a8d6cdca3 · copy
Where a conflict of interest arises, whether in dealings with Related Parties or otherwise, the Fund Manager must disclose to Unitholders the nature of the conflict and how the conflict will be managed.
Normative text · Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 · CIS V8 7.6(b) · retrieved 2026-10-23 · SHA-256 733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7 · copy
whether in dealings with Associates Related Parties
Amending act · Collective Investment Scheme Rules A7., with amendments as of 15 December 2024, commence on 1 January 2025 · Amendments No. 7, page 14 (labelled '8.7') · retrieved 2026-10-23 · SHA-256 26b1d661daa1376ede349c4366d802d11b0d58158c0ec1fcbf4da71a8d6cdca3 · copy
For the purposes of these Rules, a Fund invests in Digital Assets indirectly if:
Normative text · Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 · CIS V8 1.6 · retrieved 2026-10-23 · SHA-256 733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7 · copy
For the purposes of these Rules, a Fund invests in Digital Assets indirectly if:
Amending act · Collective Investment Scheme Rules A7., with amendments as of 15 December 2024, commence on 1 January 2025 · Amendments No. 7, page 2 (1.6 underlined as new) · retrieved 2026-10-23 · SHA-256 26b1d661daa1376ede349c4366d802d11b0d58158c0ec1fcbf4da71a8d6cdca3 · copy

How to check it without Arxo's tools

  1. Open Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 and find CIS V8 2.4(b)(iii); CIS V8 2.4(b)(iii)(A); CIS V8 7.6(b); CIS V8 1.6. Compare the text with the quotation above. A copy is kept in this register: 733512c03c358cc3-cis_v8_fr0009-01.01.2025.pdf (SHA-256 733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7, copy of the official file).
  2. Open Collective Investment Scheme Rules A7., with amendments as of 15 December 2024, commence on 1 January 2025 and find Amendments No. 7, page 3 (deletions rendered); Amendments No. 7, page 14 (labelled '8.7'); Amendments No. 7, page 2 (1.6 underlined as new). Compare the text with the quotation above. A copy is kept in this register: 26b1d661daa1376e-cis_a7-01.01.2025.pdf (SHA-256 26b1d661daa1376ede349c4366d802d11b0d58158c0ec1fcbf4da71a8d6cdca3, 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

Related records

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-2026-0116, https://arxo.io/findings/ARXO-2026-0116/ (status as of 2026-10-24). Data: ARXO-2026-0116.json.