What Freedom Holding Corp. told the SEC could break it.

As of March 31, 2026, subsidiaries held ~$187.8M of customer liabilities relating to sanctioned individuals/entities or persons whose sanctioned status was being confirmed — about 3% of total customer liabilities — creating OFAC/secondary-sanctions exposure.

“As of March 31, 2026, our subsidiaries Freedom KZ, Freedom Bank KZ, Freedom Global and Freedom EU collectively had customer liabilities relating to sanctioned individuals and entities or persons whose sanctioned status was being confirmed at the time of approximately $187.8 million that represented approximately 3% of our total customer liabilities as of such date.”

In July 2025 the U.S. imposed a 25% tariff on all Kazakhstan exports (later reduced to 15% after litigation/revisions), which could materially affect Freedom's Kazakhstan customers and, in turn, its operations.

“In July 2025, the Trump administration imposed increased tariffs on a number of countries, including a 25% tariff on all exports from Kazakhstan to the United States, which, following litigation and revisions, was reduced to a 15% tariff regime.”

A single (unnamed) market-maker customer at the Freedom Global subsidiary generated $345.5M of fee and commission income in FY2026 — 71% of total fee and commission income (up from 56% in FY2025) — and ~17% of total revenue.

“For fiscal 2026 and 2025 , we earned fee and commission income from the market maker customer at our Freedom Global subsidiary of $345.5 million and $284.7 million , representing 71% and 56% of our total fee and commission income for fiscal 2026 and 2025.”

Approximately 84% of FY2026 total revenue and most net income, and ~63% of total assets, were attributable to operations in Kazakhstan, concentrating the business in a single emerging-market economy.

“We estimate that, for fiscal 2026, approximately 84% of our total revenue and most of our total net income was attributable to our operations in Kazakhstan, and as of March 31, 2026, approximately 63% of our total assets were attributable to our operations in Kazakhstan.”

CEO and chairman Timur Turlov beneficially owns ~69% of outstanding common stock, concentrating control and creating risk that share sales (e.g., to fund commitments) could pressure the stock and that his interests may conflict with other shareholders.

“Timur Turlov, our chief executive officer and chairman of our board, beneficially owns approximately 69% of our outstanding common stock.”

92% of sovereign bonds held were issued by the Republic of Kazakhstan, and ~83% of FY2026 trading income came from interest on Kazakhstan government/quasi-government debt — a heavy single-sovereign investment concentration.

“As of March 31, 2026, 92% of sovereign bonds we hold have been issued by the Republic of Kazakhstan, while the remaining sit across Central Asian and European countries.”

The tenge depreciated ~21.6% against the U.S. dollar from the start of FY2024 through October 2025 before partially recovering (net ~6.6% over three fiscal years), exposing Freedom's largely-Kazakhstan operations to currency risk.

“For example, since the beginning of fiscal year 2024 until October 2025, the tenge depreciated relative to the U.S. dollar by 21.6%, before partially recovering, resulting in an overall depreciation of approximately 6.6% during the three fiscal years ended March 31, 2026.”