Bank-cooperation Rules: Schedule 2 still shows the 2023 DAA capital table (Self-managed Fund row, old DATF measure), while 3.3.1 refers to the DAA rules

Rule 3.3.1 of the Rules and mechanisms of cooperation with second-tier banks requires Digital Asset Service Providers to hold minimum capital "in accordance with rules 2.2. and 3.2" of the DAA, and 3.3.2 says the amounts "are specified in Schedule 2". Schedule 2, both in the PDF on aifc.kz (approved 11 December 2023) and on the regulator's website, still has (1) the row "Managing a Collective Investment Scheme, which is a Self-managed Fund ..." with USD 200,000, which the DAA no longer contains (it is absent from the consolidated version in force from 1 January 2025), and (2) the old measure for operating a Digital Asset Trading Facility: "sufficient working capital ... in different market conditions (both negative and positive scenarios)". Since 1 January 2026 the DAA uses "operational expenses in fiat currency". The other rows match. It is not clear which source governs.

Proposed correction

Please confirm whether Schedule 2 is meant to set its own amounts or only to reproduce the DAA, and then update Schedule 2 to the current DAA tables or replace it with a reference to DAA 2.2 and 3.2.

Jurisdiction

Kazakhstan — AIFC

Act

Rules and mechanisms of cooperation of unbacked digital asset exchanges and Centre Participants with second-tier banks of the Republic of Kazakhstan

Place

Cooperation Rules 3.3.2

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 amounts of minimum capital of Digital Asset Service Providers are specified in Schedule

Digital Asset Service Providers are required to provide a minimum amount of capital in accordance with rules 2.2. and 3.2 of the of the AIFC Rules On Digital Asset Activities

equal to sufficient working capital in fiat

which is a Self-managed Fund and has an

equal to operational expenses in fiat currency

which is a Self-managed Fund and has an

The amounts of minimum capital of Digital Asset Service Providers are specified in Schedule 2 to these Rules.

which is a Self-managed Fund and has an appointed Eligible Custodian

an amount equal to sufficient working capital in fiat currency to continue business for a period of 12 months, based on realistic forecasts for the business in different market conditions (both negative and positive scenarios)

How to check it without Arxo's tools

1. Open Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka and find Cooperation Rules 3.3.2; Cooperation Rules 3.3.1; Cooperation Rules Schedule 2, DATF row (rendered page checked); Cooperation Rules Schedule 2, Self-managed Fund row. Compare the text with the quotation above. A copy is kept in this register: fdae78fa000df953-rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan.pdf (SHA-256 fdae78fa000df953b46f14532a045d8ece13715191fae067b45554b2d12509c0, copy of the official file).
2. 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 Table 1, DATF row (rendered page checked). 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).
3. Open AIFC Rules on Digital Asset Activities Initial Version and find DAA initial version Table 2 - the row Schedule 2 copies. Compare the text with the quotation above. A copy is kept in this register: b2e861a30dc0572c-aifc-rules-on-digital-asset-activities-daa_stablecoins.pdf (SHA-256 b2e861a30dc0572cad84b883e338a785dd3bc1239d668642df59d25fa86e7c0c, copy of the official file).
4. Open https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan and find Regulator's website (orderly.myafsa.com), Cooperation Rules 3.3.2; Regulator's website, Cooperation Rules Schedule 2, Self-managed Fund row; Regulator's website, Cooperation Rules Schedule 2, DATF row. Compare the text with the quotation above. A copy is kept in this register: b0b62a22bf8c5cfe-orderly-coop.html (SHA-256 b0b62a22bf8c5cfe4282768d0211035dea0d51e570bd610930c2439070cd2dae, copy of the official file).
5. 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

• Rules and mechanisms of cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants authorized to carry out digital assets-related activities with second-tier bank of the Republic of Ka
• 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 Initial Version
• https://orderly.myafsa.com/entiresection/a0001000200020011/rules-of-cooperation-between-datfs-dasps-and-second-tier-banks-of-kazakhstan

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-2026-0169, https://arxo.io/findings/ARXO-2026-0169/ (status as of 2026-10-24). Data: ARXO-2026-0169.json.