ARXO-2026-0155 · Reported
DAA 4.4(2) in Part 4 (money services / stablecoin issuers) addresses 'a Digital Asset Trading Facility Operator'
4.4(2) - the only Board-of-Directors rule in Part 4 - repeats verbatim 2.3.2(1) for a 'Digital Asset Trading Facility Operator', which is regulated by Chapter 2. 4.4(1), (3) and (4) address the Digital Asset Service Provider. Amendments No. 4 edited this very subrule (deleting the one-third independence sentence and its note) and left the addressee unchanged.
Proposed correction
Please replace "Digital Asset Trading Facility Operator" (twice) with "Digital Asset Service Provider" in 4.4(2), as in 4.4(1), (3) and (4).
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Rules on Digital Asset Activities (DAA), V5
- Place
- DAA V5, 4.4(2) (identical sentence also at 2.3.2(1), p.12)
- 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.
A Digital Asset Trading Facility Operator must have an effective Board of Directors which is collectively accountable for ensuring that the Digital Asset Trading Facility Operator’s business is managed prudently and soundly.Members of the Governing Body of the Digital Asset Service Provider must have sufficiently good reputeNote: Rule 4.4 (2) will come into force 12 months after the commencement of these Rules.
How to check it without Arxo's tools
- Open AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) and find DAA V5, 4.4(2) (identical sentence also at 2.3.2(1), p.12); DAA V5, 4.4(3). Compare the text with the quotation above. A copy is kept in this register: 4a5174f747a66c22-daa_v5_01.01.2026.pdf (SHA-256
4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557, copy of the official file). - Open AIFC Rules on Digital Asset Activities A10., with amendments as of 7 December 2025, which commence on 1 January 2026 and find Amendments No. 4, 4.4(2) - strikes only the independence sentence and the Note (rendered p.12). Compare the text with the quotation above. A copy is kept in this register: e781dd1ef6743813-aifc-rules-on-digital-asset-activities-a10.-with-amendments-as-of-7-december-2025-which-commence-on-1-january-2026.pdf (SHA-256
e781dd1ef67438139fa2862aec1bf407847612ab1ac55fed4ae48118b6ed9c4d, 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
- AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026)
- AIFC Rules on Digital Asset Activities A10., with amendments as of 7 December 2025, which commence on 1 January 2026
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-2026-0155, https://arxo.io/findings/ARXO-2026-0155/ (status as of 2026-10-24). Data: ARXO-2026-0155.json.