Bank-cooperation Rules 3.1.1: the USD 1,000 monthly limit is on "depositing", but 3.1.3 and the Guidance treat it as a limit on investments (purchases)

Rule 3.1.1 requires controls preventing individual Retail Clients resident in Kazakhstan (unless they pass the provider's test) "from depositing more than 1,000 (one thousand) USD within one calendar month". The heading of 3.1 is "Limits for investing", rule 3.1.3 speaks of "the limits on investments in Digital Assets" as provided under rule 3.1.1, and the Guidance says: "Only purchase transactions of Digital Assets in the jurisdiction of the Centre are taken into account when calculating the limit." Deposits and purchases can differ: a client may deposit USD 3,000 and buy for USD 900, or deposit USD 900 and buy for USD 3,000 using sale proceeds.

Proposed correction

Please clarify whether the limit measures deposits or purchases (and whether any netting is permitted), and align rule 3.1.1 and the Guidance.

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 3.1.1

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.

from depositing more than 1,000 (one thousand) USD within one calendar month.

Only purchase transactions of Digital Assets in the jurisdiction of the Centre are taken into account when calculating the limit.

Limits for investing

ensures compliance with the limits on investments in Digital Assets by individual Retail Clients

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 3.1.1; Cooperation Rules, Guidance to 3.1.3; Cooperation Rules 3.1 heading; Cooperation Rules 3.1.3. 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. 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

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-2026-0170, https://arxo.io/findings/ARXO-2026-0170/ (status as of 2026-10-24). Data: ARXO-2026-0170.json.