Arxo Findings Register · Arxo Law

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.
Normative text · AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) · DAA V5, 4.4(2) (identical sentence also at 2.3.2(1), p.12) · retrieved 2026-10-23 · SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557 · copy
Members of the Governing Body of the Digital Asset Service Provider must have sufficiently good repute
Normative text · AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) · DAA V5, 4.4(3) · retrieved 2026-10-23 · SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557 · copy
Note: Rule 4.4 (2) will come into force 12 months after the commencement of these Rules.
Amending act · AIFC Rules on Digital Asset Activities A10., with amendments as of 7 December 2025, which commence on 1 January 2026 · Amendments No. 4, 4.4(2) - strikes only the independence sentence and the Note (rendered p.12) · retrieved 2026-10-23 · SHA-256 e781dd1ef67438139fa2862aec1bf407847612ab1ac55fed4ae48118b6ed9c4d · copy

How to check it without Arxo's tools

  1. 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).
  2. 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).
  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

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-2026-0155, https://arxo.io/findings/ARXO-2026-0155/ (status as of 2026-10-24). Data: ARXO-2026-0155.json.