PMS Part 3 application statement can be read as limiting Part 3 to digital-asset money services, although the Part 3 rules address every Money Service Provider

The opening statement of PMS Part 3 reads: "This Part 3 applies to activities of Providing Money Services in relation to Digital Assets and issuing Fiat stablecoins, except for PMS 3.1 ..., PMS 3.2 ..., 3.4." It can be read as an additional application (Part 3, except 3.1, 3.2 and 3.4, also applies to digital-asset activities), which matches PMS 1.1, the rules addressed to "a Money Service Provider" and the Guidance in DAA Part 4. It can also be read as limiting Part 3 to digital-asset activities. The statement does not mention Commodity stablecoins.

Proposed correction

Please redraft the statement so that it says plainly that Part 3 applies to every Money Service Provider and that PMS 3.1, 3.2 and 3.4 do not apply to Providing Money Services in relation to Digital Assets and to issuing Fiat stablecoins, and confirm whether issuers of Commodity stablecoins should be treated in the same way.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Providing Money Services (PMS)

Place

PMS Part 3, application statement

Record

Question of reading or data

Class

Question of reading or data

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.

This Part 3 applies to activities of Providing Money Services in relation to Digital Assets and issuing Fiat stablecoins, except for PMS 3.1. (Systems and controls)

Money Service Provider must apply Strong Customer Authentication where a Client:

apply to a Money Service Provider carrying on Money Services, in or from the AIFC.

How to check it without Arxo's tools

1. Open AIFC Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026) and find PMS Part 3, application statement; PMS 3.9.1(1); PMS 1.1. Compare the text with the quotation above. A copy is kept in this register: 333935eb310b57bc-pms-rulebook-25.05.2025_-v.1.pdf (SHA-256 333935eb310b57bcba51ab477b3e11e65a88e7ccf094eda06bc4e023e4fdac1a, copy of the official file).
2. 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 Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026)

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-2026-0162, https://arxo.io/findings/ARXO-2026-0162/ (status as of 2026-10-24). Data: ARXO-2026-0162.json.