Arxo Findings Register · Arxo Law

ARXO-2026-0167 · Reported

AUD Annex C (Insurance Intermediary Auditor's Report) measures client money 'in accordance with COB 11', which has no client-money rules

AUD Annex C (Insurance Intermediary Auditor's Report), paragraphs (a) and (b)(i), measure client money "in accordance with COB 11", while (b)(iii)-(iv) refer to COB 8. The client-money rules for insurance intermediaries were added to COB as section 8.5 in December 2018; COB 11 now ends at 11.7.7 and contains no client-money rules. The meaning can be recovered from (b)(iii)-(iv) and the title of the Annex.

Proposed correction

Please replace "COB 11" with "COB 8.5" in Annex C (an editorial correction under section 19(3)(a) of the AIFC Regulations on AIFC Acts).

Jurisdiction
Kazakhstan — AIFC
Act
AIFC Auditor Rules
Place
AUD Annex C(a)
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.

the amount of Client Money the Insurance Intermediary was holding and controlling in accordance with COB 11
Normative text · AIFC Auditor Rules · AUD Annex C(a) · retrieved 2026-10-23 · SHA-256 b7eb7eed75dfea7f0aefc2937b881836c3b1a7ba4f59701ec90fcfec5af4fae3 · copy
any of the requirements in COB 8 have not been met;
Normative text · AIFC Auditor Rules · AUD Annex C(b)(iii) · retrieved 2026-10-23 · SHA-256 b7eb7eed75dfea7f0aefc2937b881836c3b1a7ba4f59701ec90fcfec5af4fae3 · copy
AMENDMENTS No. 2.1
Amending act · Conduct Of Business Rules A2., with amendments as of 2 December 2018, commence on 2 December 2018 · COB Amendments No. 2.1 (approved 2 December 2018), cover · retrieved 2026-10-23 · SHA-256 e9854ad17038b6576e3910da0808eb63798044691da4aeab0752173116b85839 · copy
Client money: Insurance Intermediation and Insurance Management
Amending act · Conduct Of Business Rules A2., with amendments as of 2 December 2018, commence on 2 December 2018 · COB Amendments No. 2.1, new section 8.5 heading · retrieved 2026-10-23 · SHA-256 e9854ad17038b6576e3910da0808eb63798044691da4aeab0752173116b85839 · copy

How to check it without Arxo's tools

  1. Open AIFC Auditor Rules and find AUD Annex C(a); AUD Annex C(b)(iii). Compare the text with the quotation above. A copy is kept in this register: b7eb7eed75dfea7f-aifc-auditor-rules.pdf (SHA-256 b7eb7eed75dfea7f0aefc2937b881836c3b1a7ba4f59701ec90fcfec5af4fae3, copy of the official file).
  2. Open Conduct Of Business Rules A2., with amendments as of 2 December 2018, commence on 2 December 2018 and find COB Amendments No. 2.1 (approved 2 December 2018), cover; COB Amendments No. 2.1, new section 8.5 heading. Compare the text with the quotation above. A copy is kept in this register: e9854ad17038b657-cob_a2_02.12.2018.pdf (SHA-256 e9854ad17038b6576e3910da0808eb63798044691da4aeab0752173116b85839, 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-2026-0167, https://arxo.io/findings/ARXO-2026-0167/ (status as of 2026-10-24). Data: ARXO-2026-0167.json.