"Insurance Manager" (an addressee of PRU(INT)) has no definition; PRU(INT) 1.3(2) uses "Insurance Mediation" instead of the GEN activity "Insurance Intermediation"

PRU(INT) 1.3(1) applies the rules to "Insurance Intermediaries and Insurance Managers". The Glossary defines Insurance Intermediary but has no entry for Insurance Manager, and GEN defines the activity "Insurance Management" (Schedule 1, paragraph 24) but not the term "Insurance Manager". The addressee can be identified as a firm licensed for Insurance Management, but no text says so; the AFSA's Guidance to the AIFC Captive Insurance Regime states that "Insurance Manager is defined in the AIFC General Rules". Separately, 1.3(2) speaks of "an Authorisation to carry on Insurance Mediation"; the Regulated Activity is "Insurance Intermediation" (GEN Schedule 1, paragraph 15).

Proposed correction

Please add a Glossary definition, for example "Insurance Manager: an Authorised Firm whose Licence authorises it to carry on the Regulated Activity of Insurance Management", and read "Insurance Intermediation" for "Insurance Mediation" in PRU(INT) 1.3(2).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Prudential Rules for Insurance Intermediaries

Place

PRU(INT) 1.3(1)

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.

These PRU(INT) Rules apply to Insurance Intermediaries and Insurance Managers.

Authorisation to carry on Insurance Mediation

The Regulated Activity as defined in paragraph 15 of Schedule 1 of GEN.

24. Insurance Management

Insurance Manager is defined in the AIFC General Rules as a company that performs underwriting or

These PRU(INT) Rules apply to Insurance Intermediaries.

How to check it without Arxo's tools

1. Open AIFC Prudential Rules for Insurance Intermediaries and find PRU(INT) 1.3(1); PRU(INT) 1.3(2). Compare the text with the quotation above. A copy is kept in this register: 95c1086b7275b201-aifc-prudential-rules-for-insurance-intermediaries.pdf (SHA-256 95c1086b7275b2017295e0ff412b026dca70f8f441cb325d3c9d5581c8fa4e93, copy of the official file).
2. Open AIFC Glossary (GLO), V23 and find Glossary V23 'Insurance Intermediation' (no 'Insurance Manager' entry). 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).
3. Open AIFC General Rules (GEN), V20 and find GEN V20 Schedule 1 para 24. Compare the text with the quotation above. A copy is kept in this register: e863a30c73072b03-gen-v20.pdf (SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681, copy of the official file).
4. Open Guidance to the AIFC Captive Insurance Regime for Captive Insurers and Captive Insurance Managers and find AFSA captive guidance p.3. Compare the text with the quotation above. A copy is kept in this register: fb612ca7e20ee6e5-guidance-to-the-aifc-captive-insurance-regime_13.12.2020.pdf (SHA-256 fb612ca7e20ee6e5f1cfaa2752c2938f6761f8cd313fd597fed62006a85d1630, copy of the official file).
5. Open AIFC Prudential Rules for Insurance Intermediaries (initial release) and find PRU(INT) initial release (10.12.2017), 1.3(1). Compare the text with the quotation above. A copy is kept in this register: 8738528f0e70835f-aifc-prudential-rules-for-insurance-intermediaries-initial-release.pdf (SHA-256 8738528f0e70835ff98ef80f7b5e8a23cfd99c833f2e92697151735145a45cd9, copy of the official file).
6. 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

• AIFC Prudential Rules for Insurance Intermediaries
• AIFC Glossary (GLO), V23
• AIFC General Rules (GEN), V20
• Guidance to the AIFC Captive Insurance Regime for Captive Insurers and Captive Insurance Managers
• AIFC Prudential Rules for Insurance Intermediaries (initial release)

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-2026-0142, https://arxo.io/findings/ARXO-2026-0142/ (status as of 2026-10-24). Data: ARXO-2026-0142.json.