Initial Disclosure: After extensive research, we have taken a short position in shares of Freedom Holding Corp. (NASDAQ:FRHC). This report represents our opinion, and we encourage every reader to do their own due diligence. Please see our full disclaimer at the bottom of the report.
Freedom Holdings is an online retail brokerage business based in Kazakhstan that generates around 71% of its total revenue from Central Asia and Eastern Europe. [Pg. 9] In addition to brokerage services, the company offers a range of other financial services including investment counseling, banking, and insurance products. [1,2,3]
The retail trading mania during the pandemic helped propel rapid account growth for Freedom. As of March 31, 2020, the company reported 140,000 client accounts. [Pg. 2] By 2023, just three years later, that number grew to 370,000 client accounts.
In February 2023, Freedom announced it would further its “strategy of acquisitions” and expand its presence in the U.S. investment banking industry through a $400 million bid for Maxim Group, a low-tier investment bank. 
Since listing on NASDAQ in 2019, Freedom’s shares have rocketed over 450%, trading just ~9% off all-time highs with a market cap of $4.6 billion.
Despite this, even if one were to take Freedom’s reported fundamentals at face value (which requires ignoring numerous red flags), the company trades at an elevated 5.3x sales and 22x earnings. By comparison, peers in similar riskier jurisdictions like XTB and Plus500 trade at ~5.3x earnings.
In a 2020 presentation, prior to the Russian invasion of Ukraine, Freedom emphasized that Russia and Ukraine, collectively, accounted for 2 of its top 3 key “strategy and growth drivers”.
Yet after Russia’s invasion of Ukraine, Freedom supposedly lost access to both markets:
#1 Ukraine. In October 2022, Ukrainian authorities suspended Freedom’s Ukrainian brokerage license and froze its assets following its inclusion on a government sanctions list. It remains on the list to this day.
#2 Russia. In October 2022, Freedom announced it would sell its Russian business for $140 million to an employee. The transaction was completed in February 2023.
Freedom has removed all investor presentations from its website as of this writing.
After losing the Russian market of ~144 million people and the Ukrainian market of ~44 million people, Freedom now claims its massive growth has been driven by customers in its next largest “key market”, the tiny nation of Kazakhstan, which has a population of just 19 million.
Specifically, Freedom’s 2023 revenue for Central Asia & Eastern Europe, in which its key market is Kazakhstan, stood at $566 million, increasing 154% year over year. [Pg. 73]
Kazakhstan’s income inequality and widespread poverty hardly seems to be an environment capable of delivering Freedom´s claimed growth.
In late January 2022, President Kassym-Jomart Tokayev addressed a meeting of Kazakh-based oligarchs in the wake of countrywide riots sparked by fuel price hikes. Freedom CEO Turlov was at the meeting. Tokayev said:
“International experts say that only 162 people own half of Kazakhstan’s wealth. While half of the population’s monthly income doesn’t exceed $114. That’s just over $1,300 a year. It’s almost impossible to live on such money. As I said, such stratification and inequality is dangerous.”
Key stages of Freedom´s expansion have been reached thanks to Turlov´s willingness to do business with sanctioned Russian oligarchs or Kazakh businessmen closely linked to their country´s corrupt political elites.
With business operations in strategically opaque geographic locations, Turlov and Freedom, despite their obligations under U.S. law, have seemingly defied sanctions, facilitated money laundering and aided clients in skirting currency controls to move funds out of Russia.
In its recent annual report filed on August 4, 2023, Freedom openly admitted that it provided “brokerage services to certain individuals and entities who are subject to sanctions imposed by OFAC, The European Union or the United Kingdom”. [Pg. 25]
It sought to justify these transactions by saying the very same services “did not involve any nexus with the United States, the European Union or the United Kingdom”. [Pg. 25]
In other words, Freedom – a U.S. listed company—acknowledges providing financial services to individuals who have specifically been targeted by sanctions deemed to be of U.S. national strategic importance.
According to multiple former employee interviews, Freedom Finance offices in Russia and Kazakhstan routinely channel clients into an opaque Belizean entity privately owned by Freedom’s CEO. (The entity was named FFIN Brokerage Services. It is now renamed Freedom Securities Trading and referred to here as “FFIN Belize”).
Attempting to crack open the FFIN Belize “black box” and discover its mechanics, we talked to former employees.
They told us that the FFIN Belize entity was used to funnel money out of Russia, often in cash, with no regard for KYC and AML protocols.
A former senior executive, who worked for Freedom in Russia and later in Kazakhstan between 2018-2020, described the extent of Freedom’s KYC and AML checks:
“Literally nothing. Just bring your money. There’s no source of income, source of funds. There’s no KYC. Nothing. The best part is this is violating almost every country’s anti-money and anti-terrorist financing laws. They could bring cash. I’ve personally seen suitcases with $2.5 million brought in cash by a client.”
An account manager who worked until 2023 with Freedom Finance in Russia (later renamed Cifra Broker) corroborated this:
“Actually you could even come with cash to Freedom.”
Another former employee, who worked for Freedom Holding in the UAE (before the company was incorporated there and even though it has not yet been licensed to offer financial services there) explained that meetings with clients were conducted in private rooms at high-end hotels and that cash investments were readily accepted:
“If I have to give a ballpark estimate, I think about 80% of that came from either cash or cryptocurrencies.”
The former employee said most Freedom clients in Dubai were Russian or “East European origin”. Anyone who did not pass KYC and proof-of-funds checks was re-routed to open accounts at FFIN Belize:
“We have clear guidelines. You know, if it’s a vanilla client, Cyprus. If it’s not a vanilla client, then Belize…We call it vanilla, like, you know, like clean clients, vanilla flavored, like, you know, the ice cream, vanilla. It’s like the cleanest flavor.”
“I’ll be honest with you, I think I only sent one client to the Cyprus one because the rest of all of these clients were basically to Belize accounts.”
The former employee said Freedom Holding knowingly flouted KYC rules to move dirty money:
“They were basically cowboys. They found a way to actually take the oligarch money, send it across the world, put it into the stock markets.”
“I have never seen an organization so unstructured and just blatantly like I’m sorry for my words, but taking a shit on regulations and rules and basically everything as much as this.”
These issues have persisted through the years, per our findings.
Freedom Holding Chairman & CEO Turlov incorporated his privately-held FFIN Belize in July 2014, just 4 months after Russia invaded and annexed Ukraine´s Crimea region, sparking a first wave of global sanctions.
In its filings, Freedom Holding makes no overt reference to the 2014 sanctions but does explain that Turlov set up his private, Belize-registered entity (called “FFIN Brokerage” in filings) to help investors sidestep Russian regulations and restrictions:
“July 2014, Timur Turlov established FFIN Brokerage. As a foreign broker dealer, FFIN Brokerage had been able to provide investors in Russia and Kazakhstan with easier access to the U.S. securities markets than a Russian or Kazakhstan company could provide, due to applicable regulations in Russia and Kazakhstan which imposed restrictions on foreign currency accounts, required mandatory securities custody in-country, and limited access to foreign securities” [Pg. 39]
Freedom incorporated in Russia in 2008 but its fledgling brokerage business grew significantly following Russia’s 2014 invasion of Ukrainian Crimea.
In the wake of the invasion, the U.S. sanctioned oligarchs close to Russian President Vladimir Putin. These oligarchs included Igor Sechin who served as Putin’s former Chief of Staff, Deputy Prime Minister and later CEO of state oil company Rosneft. Sechin also had control of Okhabank, a regional bank, via his role as CEO at Rosneft. 
Nicknamed “Darth Vader”, Sechin has been described as the second most important person in Russia after Putin. These international sanctions created opportunities for those willing to help oligarchs evade restrictions –including Turlov and Freedom.
Just 8 months later, in November 2015, Turlov took Freedom public in the U.S. via a reverse merger with an oil and gas company trading on the over the counter (OTC) market. [Pg. 4] The deal to purchase Okhabank from its sanctioned owners was fully completed in April 2016, five months after Freedom had gone public.
The acquisition closed at a time when U.S. sanctions prohibited U.S. citizens or entities, ostensibly including the newly listed Freedom Holding, from dealing with sanctioned individuals and corporations, like Sechin and Rosneft.
In June 2022, 4 months after Russia’s invasion of Ukraine, Turlov announced his intention to ‘divest’ the Russia business by selling it to himself. Turlov hoped the move would somehow avoid sanctions, saying the company’s most robust business would now technically “exist independently of the holding company”.
In October, Freedom instead signed an agreement to sell its Russian businesses for $140 million to an employee. The purchase price represented roughly 3.3% of the company’s market cap at the time, despite the businesses comprising 25% of its revenue and much of its claimed future growth potential. [Pg. 118] [Pgs. 4, 71]
The buyer was Maxim Povalishin, the Deputy General Director and a member of the Board of Directors of Freedom’s Russian subsidiary, per Freedom’s press release. The deal was comprised of a $51.5 million cash payment and assumption of an $88.5 million liability by the buyer.
A former senior executive of Freedom Holding who had personally worked with both Turlov and Povalishin described the sale of Freedom Finance Russia to Povalishin as a ruse to skirt sanctions:
“Maxim Povalishin, basically the buyer, he’s the head of the back office of Turlov´s Belize entity. So he’s like his childhood friend, right? And he still works there. So he just made it seem like he sold the entity to his friend for like a hundred and some million dollars. Although the guy had like $5 million to his name tops.”
“So I’m assuming what they did, what they did is he just made it seem for, you know, the purposes of sanctions and the whole image of supporting Russia and doing business in Russia, that they sold off the Russian entity. But he (Turlov) still controls it.”
As noted above, coupled with Russia, Ukraine was set to be a major “growth driver” for Freedom. [Slide 11].
According to its 2021 annual report, Freedom had a significant presence in Ukraine with 13 offices nationwide. [Pg. 7] Just two days after Freedom’s deal to shed Russian assets was signed on October 17, 2022, Ukrainian president Volodymyr Zelensky issued a decree sanctioning Freedom’ Founder and CEO Turlov, along with other individuals, for allegedly abetting the Russian regime or its financial system.
The 17 specific sanction measures included an asset freeze, a termination of all business activities, a ban on moving assets out of the country and a ban on entering Ukraine.
The Ukrainian asset freeze included 12,800 Freedom customer accounts and about U.S. $95 million in assets, along with a suspension of Freedom’s Ukrainian brokerage license for 5 years.
Freedom issued a press release two days after the decree saying it was “stunned” to learn of the decision by Ukrainian authorities, calling it an “error”. It stated that its agreement to divest Russian assets to an employee, made less than a week earlier, and Turlov´s adoption of Kazakh citizenship 3 months earlier in June 2022 were signs the company had severed ties with Russia.
The company said it believed the sanctions would “be resolved quickly.”
Current checks of Ukrainian government sanction lists show that the sanctions are still active.
Since the invasion of Ukraine, Kazakhstan has tried to balance the role of being a key Russian ally while maintaining cordial relations with the West.
There is growing evidence, and concern from the U.S. Treasury Department, that Kazakhstan has become the “Kremlin´s Secret Ally”, helping Russia circumvent wartime sanctions, moving banned goods in and helping hundreds of thousands of Russians move money out.
As such, Kazakhstan is an important bridgehead for Freedom from which it can continue to attract Russian money while retaining access to global markets.
A recent former employee of Freedom Finance´s brokerage and banking in Kazakhstan said he had witnessed a sharp, initial upturn in Russian money moving via Kazakhstan:
“After Russia invaded Ukraine, thousands of Russians came to Freedom Finance (Kazakhstan) to open accounts and transfer their assets.”
A former employee of Freedom Holding from London described the company´s scramble to prepare for the consequences of the 2022 invasion of Ukraine as “a process of taking out Russian business from our holding”.
They told us that part of that plan included handling Russian-facing business from Kazakhstan:
“Still Kazakh market is very close to Russian market, like territorially and everything, and we still can take care of the clients from Kazakh offices and stuff.”
Alfa Bank, Russia’s largest private bank, had been subject to U.S. sanctions since the start of the invasion of Ukraine in February 2022. Alfa´s founder, sanctioned multi-billionaire oligarch Mikhail Fridman, is reportedly a close associate of Russian President Vladmir Putin, described as an “enabler of Putin´s inner circle”.
On April 6, 2022, the White House and EU hit Alfa Bank with “full blocking sanctions” – some of the most severe U.S. sanctions. [1,2] The new measures meant customers would lose access to foreign securities and all transactions would be frozen.
The move effectively prohibits any U.S. citizen or entity doing business with the bank. A White House statement announcing the sanctions said:
“This action will freeze any of Sberbank’s and Alfa Bank’s assets touching the U.S financial system and prohibit U.S. persons from doing business with them…Alfa Bank is Russia’s largest privately-owned financial institution and Russia’s fourth largest financial institution overall.”
The U.S. Treasury set a deadline of until May 6, 2022 for all transactions with Alfa Bank to be terminated. Freedom Finance Russia (before it claimed to have been ‘divested’) stepped in to facilitate moving customer assets from the already sanctioned bank, when many others brokerages wouldn’t.
Freedom Finance Russia openly touted this service, according to archived copies of its website, stating “all you need to do is open an account (with Freedom Finance).”
Sanctions related to Alfa Group continue to be active and ongoing. Days ago, the U.S. Department of the Treasury announced new sanctions on “prominent members of Russia’s financial elite”.
New sanctions targeted the founder and supervisory board of Alfa Group. Deputy Secretary of the Treasury Wally Adeyemo commented:
“Wealthy Russian elites should disabuse themselves of the notion that they can operate business as usual while the Kremlin wages war against the Ukrainian people. Our international coalition will continue to hold accountable those enabling the unjustified and unprovoked invasion of Ukraine.”
Freedom continues to publicly offer clients ways to circumvent sanctions through Alfa Bank.
Turlov´s privately-owned FFIN Belize entity’s website, which displays a 2023 copyright, offers customers two options to fund their brokerage accounts in Russian rubles by depositing funds into FFIN Belize accounts in Moscow. One option is with Alfa Bank.
In short, FFIN Belize offers Russians a path to funnel rubles via one of Russia´s most heavily sanctioned banks through a Belize-licensed brokerage right onto the U.S. stock market.
One of the former senior executives we spoke to explained that clients could deposit funds in rubles or other currencies in Russia and receive funds back from FFIN Belize in U.S. dollars and/or Emirati Dirham to accounts anywhere in the world.
Alfa Bank is not the only example where Freedom appears to have helped clients move assets out of a sanctioned Russian bank.
On February 24, 2022, the U.S. Treasury announced full blocking sanctions against VTB, the second largest Russian bank, per a press release. Despite this, we found examples of customers getting around these sanctions and transferring funds via VTB into Freedom Finance.
For example, on a Telegram channel, translated as “Freedom Finance Kazakhstan – CHAT”, members shared advice on moving funds via Russia´s VTB Bank to Freedom Finance in Kazakhstan.
Customers discussed a similar VTB scheme in another online public forum on the popular Russian travel site Awd.ru, under a heading translated as “transferring money from Russia to your account in Kazakhstan”. The posts name Freedom Finance Kazakhstan as a bank accepting transfers from VTB.
The scheme was explained by a user as involving a multi layered transaction: 1) Purchase Kazakh Tenge currency through VTB; 2) Withdraw funds to a VTB Account; 3) Send the funds to Freedom Finance. [Post 5340]
One user on July 5th, 2022 stated that Freedom Finance had accepted this type of transfer, while another Kazakh bank, BCC, had rejected it.
Amid the influx of Russians to Kazakhstan, Tinkoff Bank – placed on EU and UK sanctions lists in February 2023 and May 2023, and on the U.S. sanctions list on July 20, 2023– advised its premium customers to open accounts remotely with Freedom Bank Kazakhstan, according to Forbes Russia.  
The head of Tinkoff Bank’s investment arm, Tinkoff Investments, is Dmitry Panchenko, a longtime associate of Turlov who was Deputy CEO of Freedom Finance RU from 2011-2019, according to his LinkedIn profile.
In sum, we are left to assume that Freedom Holding’s growth in Kazakhstan is likely to have come from using Kazakhstan as a surreptitious bridge into Russia, rather than organic domestic growth.
The U.S. government has enforced its Russian sanctions through an intensive global campaign:
“We’ve grounded planes in Switzerland and the Middle East. We’ve arrested smugglers in Italy, in Germany, in Latvia. And we’ve charged money launderers in the U.K. So basically, what we’ve shown is there’s no place to hide,” U.S. Deputy Attorney General Lisa Monaco told 60 Minutes.
Given these ongoing widespread international enforcement efforts, we find surprising that Freedom has managed to hide in plain sight as a U.S.-listed public company trading on the Nasdaq.
Beyond sanctions, Freedom seems to be engaged in a broad variety of corporate malfeasance involving the same Belizean entity privately owned by its Chairman & CEO, Timur Turlov.
Normally when one customer makes up a considerable concentration of a public company’s revenue, investors are provided thorough detail on the relationship.
In the case of Freedom, its largest contributor to revenue comes from CEO Timur Turlov’s “black box” Belizean entity. Given Turlov’s unique insight into this “customer”, these circumstances would normally prompt fulsome disclosure about its operations.
Except, in this case of Freedom’s largest contributor to revenue, we get the opposite: paltry disclosure and questionable financials from an entity with virtually no physical signs of existence.
In the lead up to Freedom’s uplisting to NASDAQ in 2019, pressure to show solid performance mounted. SEC filings show that Freedom’s reliance on related parties for its claimed brokerage revenue exploded.
Related parties as a percentage of total revenue increased from 10.9% in fiscal year 2018, to 52% in fiscal year 2019. By fiscal year 2020, related parties accounted for 67.5% of Freedom’s total reported revenue.
Despite the massive reliance on, and risk tied to these related parties, Freedom chose not to disclose details on the specific entities involved. Instead, it listed revenue values for unnamed related party transactions, such as Note 23 in Freedom’s 2020 annual report, disclosing commission income earned from unnamed related parties:
This lack of disclosure didn’t go unnoticed by regulators. In 2022, the Public Company Accounting Oversight Board (PCAOB) announced sanctions against three accountants at Freedom’s auditor, Utah-based WSRP, for failures relating to its accounting of Freedom’s relationship with related parties.
According to the PCAOB, two WSRP partners failed to “Identify that Freedom’s 2019 and 2020 financial statements did not contain necessary disclosures regarding a related party and its relationship with Freedom and its CEO”.
The PCAOB order specifically identified the entity as a “Belize Affiliate” owned by Freedom’s CEO.
A December 2020 exposé by the Foundation for Financial Journalism first revealed the extent of Freedom’s dealings with the unnamed related party driving revenue growth, called FFIN Brokerage Services (now renamed Freedom Securities Trading and referred to here as “FFIN Belize”).
Prior to 2021, Freedom’s annual and quarterly SEC filings made no reference to FFIN Belize driving related party revenue growth.
Following the exposé, in its 2021 annual report, Freedom disclosed that FFIN Belize was privately controlled by Turlov and that the entity posed a significant risk to Freedom due to revenue concentration and “evolving market regulations”.
In restated SEC filings for fiscal year 2021, Freedom disclosed that FFIN Belize accounted for a material 19% of Freedom’s total revenue. [Pgs. 62, 65]
Several months after the exposé and around the same time as the new disclosure in Freedom’s SEC filings, a financial statement for the year ended 2020 was posted to FFIN Belize’s website.
The financial statement raises more questions than it answers. FFIN Belize reported only $5.4 million in cash and minimal other account balances, while also reporting over $2.465 billion in receivables and $2.562 billion of payables balances.
In other words, the entity most crucial to Freedom’s top line supposedly carried a cash position of just ~0.2% of its payable and receivable accounts, indicating that these accounts are not settling in cash in any meaningful fashion.
For context, if FFIN hypothetically converted a paltry 5% of its receivables to cash, it would be expected to have ~$123 million on its books, nearly 25 times what it held.
We have not been able to find any updates on FFIN’s financial statements since the lone 2020 audit, but we think Freedom should share all FFIN Belize audits with investors given its shared ownership and critical importance to the public entity.
The claimed revenue contribution from FFIN Belize has grown rapidly from $48.4 million in 2020 to $196.3 million in fiscal year 2023. This represented over 29% of Freedom Holding’s total revenue in the past 3 years. [Pgs. 63, 125 & Pgs. 62, 95]
With such an acute level of risk tied to an opaque related party, one might expect Freedom to disclose significant information, but Freedom provides no information on the beneficiaries of these loans.
Even stranger is Freedom’s claim that it can’t provide more detail because it does not have “direct access to information on FFIN Belize’s customers,” despite Freedom’s own Chairman & CEO running and controlling the entity.Per the company’s December 2022 10-Q:
“For margin lending to FFIN Brokerage [Belize], these risks may be increased by the fact that we do not have direct access to information on FFIN Brokerage’s [Belize’s] customers, who are the ultimate recipients of the loans.” [Pg. 96]
In its March 2023 10-K, Freedom reiterated that “we do not currently have direct access to FST Belize’s customer check systems.” [Pg. 25]
Because FFIN Belize is technically privately controlled, it is not subject to the same SEC reporting requirements and disclosure rules as Freedom’s listed entity. This means that, despite Turlov overseeing the brokerage and likely having a full grasp on its business, this crucial contributor to the listed entity’s financials, is essentially a conveniently timed, rapidly growing, black box – all by Turlov’s choice.
In summary, FFIN Belize’s financials indicate that Freedom is likely using customer assets to report fake revenue through opaque circular transactions with Turlov entities and affiliates.
As detailed earlier in Part I, per interviews with former employees, Freedom’s ‘high-risk’ customers are diverted to FFIN Belize, a structure that effectively bypasses Anti-Money Laundering (AML) and Know-Your-Customer (KYC) requirements, as well as evades sanctions and other potential compliance issues.
Once those assets are in the control of the Belize entity, they appear to be used in suspicious circular revenue transactions that inflate Freedom’s claimed revenue to investors, as detailed in Part II.
Beyond those critical issues, we have identified signs that FFIN Belize’s customer assets have been further misused by Turlov.
Freedom’s customers seem to believe the company’s related-party Belize entity is a trustworthy tool for deploying capital to western markets. But evidence shows that Turlov has commingled the entity’s assets and used them to take on massive leverage and trading risks, exposing customers to potential capital loss.
Every credible brokerage and banking firm segregates customer assets in order to ringfence and protect them in case the firm runs into trouble. Most major crises involving failed brokerage firms (FTX, Celsius Network and MF Global, among many examples) have occurred because the firms in question violated this basic customer safety principle.
FFIN Belize’s website contains a risk disclosure statement, which deals with “risks associated with operations in the securities market”. Within it, FFIN Belize deems its clients to have accepted and acknowledged the risks of highly unusual operations, including allowing the entity to use their funds/securities “in its own interests” via a “special brokerage account”. [Pg. 11]
FFIN Belize admits it unifies client funds in one account, which may lead to customer’s money being written off. [Pg. 12] FFIN Belize also states “the Company shall have the right to use the Client’s monetary funds/securities in its own interests free of charge”.
In other words, customers of FFIN Belize are allowing their funds or securities to be used discretionarily, for purposes unknown, by Turlov. The risk statement even acknowledges the “peculiarities of the functioning of special brokerage accounts”, likely given that it violates the brokerage industry’s single most critical customer safeguard. [Pg. 12]
We believe such disclosures are an attempt to provide legal cover and carte blanche authorization for highly irregular conduct that puts customer assets at extreme risk.
As we noted above, FFIN Belize’s website added a financial statement from the year ended 2020 that showed hallmarks of circular revenue transactions. The same financial statements also raise questions about misappropriation of customer funds.
FFIN Belize’s audit did not report any “ringfenced” customer assets, a distinction that makes clear which assets belong to the brokerage versus the customer. This stands at odds with virtually every other major brokerage business.
For U.S. issuers, SEC Rule 15c3-3 governs segregation of client assets from the firm’s assets. The purpose of such segregation is to allow clients to obtain their assets if the firm becomes insolvent. Regulatory agencies like FINRA also note the importance of such obligations as a safeguard for customer assets:
“Firms are obligated to maintain custody of customer securities and safeguard customer cash by segregating these assets from the firm’s proprietary business activities, and promptly deliver to their owner upon request.”
IPO allocations are near-impossible to source for retail traders and even difficult to source for many of the most connected investors on Wall Street.
Yet one key offering promoted by Freedom has been its ability to give customers access to popular IPOs.
When questioned on this offering, Turlov claimed that little-known Freedom sources its numerous IPO allocations through shadowy means, explaining to Bloomberg in August 2021 that its IPO offerings were routed through a “mystery hedge fund”.
According to the article, Freedom’s related party, FFIN Belize, purchased IPO stock from a “mystery” affiliated hedge fund which Freedom then monetizes:
“Turlov has that Belize-registered entity, FFIN Brokerage Services Inc., buy it [IPO stock from the affiliate] and eventually pass it to Freedom for a fee.”
No more detail on the mystery fund was provided, begging obvious questions as to why this unnamed fund is so comfortable handing generous revenue economics to FFIN Belize. Turlov seems to have made no effort to explain why the mystery fund can’t simply work with Freedom directly and instead must go through Turlov’s private Belizean entity. This chart shows the unnecessarily convoluted process:
To learn more about the hedge fund, we reached out to a former Freedom account manager who told us they were unaware of the mystery hedge fund. “No one knows”, they said when asked about who it was. They added:
“My suspicion is that there is no actual IPO…that you have a kind of stock allocation, but you have some kind of derivatives…. I don’t think that it’s a really actual allocation and my mind I think that this is some kind of derivatives.” 
A trait that many investment schemes share, particularly Ponzi schemes, is enticing in new money with promises of high returns, whether IPO returns or others. “Be highly suspicious of any ‘guaranteed’ investment opportunity,” the SEC warns investors.
On various Russian language message boards, Freedom users have detailed suspiciously high, guaranteed return products, such as the one below claiming a 25% guaranteed return.
The issue eventually caught the eye of Kazakhstan’s financial market regulator, which blacklisted Freedom’s key related party entity, FFIN Belize, in October of 2021 for ‘signs of illegal activity in the territory of Kazakhstan’ relating to offering products that guarantee returns. The blacklist does not shut down FFIN’s operations in the country, but serves as a clear warning to potential customers.
In a media statement, FFIN Belize denied it was engaged in any illegal activity.
A subsequent February 2023 Kazakh government notice still showed FFIN on the blacklist.
One former senior Freedom executive we spoke with was very familiar with the operations of FFIN Belize while they were at the company around 2020.
Based on their first-hand experience, the former executive told us that Freedom Russia clients were routinely advised to open accounts with the Belize entity to gain better access to U.S. stock markets.
Freedom Holding’s infrastructure was effectively serving as a front office to funnel clients to Turlov´s privately-owned offshore entity, we were told:
“So the traders, the trading desk, the back office lawyers, they were all in Moscow. But as far as I know, the trade desk has moved to Cyprus now. In Belize there’s no presence at all. Never has been any presence in Belize.”
“So they (Freedom Holding) have a Russian license from the Central Bank of Russia to provide brokerage services. And they have offices in almost every city in Russia. There’s like 40 offices, right? What happens when a client goes in there? He goes, well, through this entity, there’s a bank and there’s a brokerage you can only trade like a handful of securities. If you want real access to US markets, if you want access to IPOs, U.S. IPOs, then you need to become a client of Freedom Belize. So basically, every client that comes in into a Russian office is diverted to Belize.”
They also told us that FFIN Belize frequently didn’t execute client trades:
“So they would take the cash and then they basically would send them a report that now your account has this much cash you can trade. Then we found out that they don’t actually execute trades. So where the money goes, nobody knows.” 
The former employee continued to explain a situation where FFIN Belize received customer assets but wasn’t trading the securities in question. Instead, Turlov was using the company as “his own personal piggy bank”, we were told:
“Because Freedom Belize is not part of Freedom Holding. So essentially, since Freedom Belize is his own personal piggy bank, let’s call it that, it’s the largest client of Freedom Europe, which is Cyprus. Then he just pays that company commission every quarter or whatever he thinks he feels like.”
The executive told us that prior to his leaving the firm he had an argument with Turlov regarding the “Belize” operations:
“I had the question. I’m like, well, what do you do with the money? You just collected billions of dollars into this Belize entity. If you don’t make the trades, what do you do with the money? And then he (Turlov) goes, it’s a good business when statistically 90% of retail traders lose money over time. It’s a good business model. That was his actual words to me, right?”
He then shared his overall take:
“So they just do like some kind of fixed income stuff and kind of hope that the client will eventually lose money and they have to give them less than he gave them originally. That’s the business model of the Belize entity.”
Another former employee for Freedom in Dubai echoed that there was no clarity on how actual trading was executed, if at all:
“I’ll be honest, my understanding of how this worked was that, you know, the actual client money, like actual original clients, never really made it anywhere. So those were just kept in as buffer stock or something in these entities in Belize and Cyprus, whereas, you know, they were using some funding or… For them, I wouldn’t even be surprised if all of this was all manipulated and they weren’t even investing in stocks.”
Combined with lingering questions about its revenue, we believe FFIN Belize is misappropriating, misusing, or simply holding its brokerage customers money instead of investing it.
Once commingled, Freedom seems be gambling customer assets, taking on massive, leveraged market risk.
Despite Freedom’s primary focus being the retail brokerage industry, the company has generated 9%-59% of its revenue from proprietary trading from 2017 to present, with no reported down years.
In 2023, Freedom reported that proprietary trading contributed over $71 million, or 9% of overall revenue.
Freedom’s massive proprietary gains come with seemingly little risk, according to Freedom’s 2022 annual report. The filing said Freedom adheres to “conservative risk management principles” with a focus on principal protection:
“Our investment policies generally require securities to be investment grade and limit the amount of credit exposure to any one issuer or customer.” [Pg. 6]
According to Freedom’s financial statements at the end of fiscal year 2023, it held a $835 million dollar stake in the debt of an issuer called the Kazakhstan Sustainability Fund JSC, a fund owned by the National Bank of the Republic of Kazakhstan that supports second tier Kazakh banks and provides mortgages in the country. [Pg. 125]
The position represented 35% of Freedom’s trading balance, as of the March 2023 annual report.
Freedom’s financial statements disclose that as of March 2023, its $2.4 billion in trading securities were financed largely with short term leverage. [Pg. 39] The company disclosed $1.5 billion dollars in short term funding from “securities sold under repurchase agreements”, 96% of which had a maturity of up to 30 days. [Pg. 135]
Reliance on such high, short-term leverage poses a significant risk if the liquidity or value of the underlying collateral suffers.
While Freedom does not specify exactly which bonds of the Kazakh Sustainability Fund it has invested in, Bloomberg data on all 28 reported bonds from the issuer show the underlying securities were illiquid and appear to only trade by appointment.
Of the 28 bonds, 13 had no volume over the last 30 days.  The total 30-day average volume for all bonds of the issuer with volume was $16.6 million, suggesting that Freedom holds at least a full 50 days of bond volume.
Given that Freedom has financed the position with ~$1.5 billion in 30-day or shorter financing, the issuer’s illiquidity seems to pose a substantial risk, with likely massive price impact should Freedom attempt to exit its position.
This risk is enhanced given that Freedom owns roughly 38% of the total issuance of the Kazakh Sustainability Fund, making it a major holder.
Freedom’s financing strategy discussed above can be described as having “negative-carry”, a situation that arises when an investment returns less than the cost of financing the investment.
We estimate that Freedom’s $835 million stake in the Kazakh Sustainability Fund is currently generating a lower return than the rate Freedom borrows at via short term repos (repurchase agreements) to finance itself.
The average mid-market yield to maturity (“Mid YTM”) of the 28 issues of the Kazakh Sustainability Fund we analyzed was 15.91%, per Bloomberg. Some bonds had yields as low as 12.07%.
By contrast, Freedom discloses its borrowing through repos of “non-US sovereign debt” and “corporate debt” at higher average interest rates of 15.98% and 16.07%, respectively, per its March 2023 annual report. [Pg. 135] This implies on average a negative, loss-making carry of between 0.06%-4%. [Pg. 135]
Worse yet, evidence suggests the price of Freedom’s bonds may have been manipulated, staving off reporting of potential catastrophic losses.
The Kazakh Financial Regulator had concluded an investigation in January 2023, finding that 22 deals with Kazakhstan Sustainability Fund JSC’s bonds were transactions “committed for the purpose of manipulation”, according to reporting by Bloomberg.
The regulator has not yet specified which market participants engaged in the manipulation.
Freedom’s holdings in the Kazakh Sustainability Fund spiked in the period when bond prices were held artificially high, indicating that Freedom’s aggressive purchases may have played a role in driving the low yields and consequent high prices.
Freedom’s bond position represents more than its entire shareholder equity balance, funded by short-term, expensive debt. This strikes us as a combination of the most dangerous elements of finance, posing an existential risk to Freedom and any of its commingled customer accounts.
Despite Freedom’s stock trading at elevated levels relative to its peers and its general risk profile, the company trades remarkably steadily on NASDAQ, with a low beta of about 1.12 and low volatility, seemingly regardless of market events.
For example, the global financial sector suffered in March 2023 with the implosion of Silicon Valley Bank and the crisis at Credit Suisse. Regional banks and brokerages sold off in March and have yet to fully recover. Yet Freedom’s stock was seemingly impervious to wider market forces, reaching a 5+ year high relative to comparables, even while other brokerages fell along with the sector.
This is but one example of Freedom’s imperviousness to many normally market-moving events.
In our effort to understand Freedom’s irregular trading patterns, we noticed a glaring anomaly.
Bloomberg collects data on trading volume that is self-reported by market participants or reported by exchanges like NASDAQ (referred to as “ECNs”).
The data shows that two brokers, Lek Securities and Vision Financial Markets, collectively comprise only about 0.07% of trading volume on the NASDAQ over the past ~1.5 years (since January 2022) yet have comprised ~60% of trading volume in Freedom’s stock over the same period.
The metrics alone are highly unusual—listed companies are generally traded somewhat in proportion to the general market for brokerages.
The concentration of trading in 2 brokerages suggests that only a very small number of individuals comprise the majority of the buy and sell volume in Freedom’s shares, a hallmark sign of market manipulation.
Further, Lek Securities and Vision Markets have deeply entrenched relationships with Freedom. Both brokers have existing clearing agreements with Freedom, likely giving them greater access and knowledge of Freedom’s operations.
Volume reported on Bloomberg shows that Lek Securities comprised over 59% of trading volume in Freedom stock in calendar year 2022, reaching as high as 70% in one month alone.
Such trading is highly unusual, even more so given Lek’s history of facilitating manipulative trading through central Asia, according to the SEC.
In March 2017 the SEC charged Lek Securities alongside a Ukrainian brokerage firm for manipulative trading that resulted in almost $30 million of illicit profits.
“As alleged in our complaint, Avalon openly marketed itself as a destination for manipulative trading, and Lek Securities opened the gate to allow the schemes into the U.S. markets despite repeated warnings that its customer was manipulating the market,”
The SEC case wasn’t Lek’s only regulatory infraction. According to its FINRA report, Lek was the subject of 42 regulatory disclosure events.
As one example, in December 2019, the company’s FINRA brokercheck shows that Lek Securities had allowed customers to engage in ~$100 million of penny-stock trades (receiving $1.6 million in commissions) despite numerous red flags of fraud. [Pg. 42]
In June 2022, Freedom Finance Europe announced a new partnership with clearing broker Vision Financial Markets, seemingly moving away from its relationship with LEK.
ECN data shows that Vision became the key broker effecting Freedom trading volume around that time.
More specifically, in June 2022, Lek and Vision each comprised about 34% of the traded volume in Freedom. Lek Securities decreased significantly in July, accounting for only 5% of the trading volume, while Vision accounted for over 63%.
Lek Securities then abruptly disappeared from transacting in the company’s stock around August, while Vision stood at 56% of the volume.
Current year to date volume shows that Vision Financial Markets accounted for ~17% of volume.
For a relatively small brokerage firm, Vision has accumulative an impressively long rap sheet of regulatory infractions.
In 2014, the National Futures Association barred Vision from the futures markets over repeated violations including helping misappropriate customer funds and use of deceptive promotional materials. [Pgs. 2-3]
The same day the NFA announced it had barred Vision, the same management team initiated plans to relaunch.
While it might come as a surprise that a barred brokerage firm can simply relaunch instantly under the exact same management, it likely won’t come as a surprise that Vision went on to accumulate a rapid array of regulatory sanctions.
The firm discloses 26 disclosable regulatory sanctions, according to its FINRA BrokerCheck report.
Among those, in March 2019, the SEC fined Vision for failure to file Suspicious Activity Reports (SARs) for over hundreds of suspicious penny stock transactions.
In a 2020 civil suit, Vision was accused of a 5-year fraudulent trading scheme to overcharge clients by $50 million from 2014 to 2019.
In 2022, FINRA fined Vision for failure to design and execute an adequate anti-money laundering program. [Pg. 29] That same year, FINRA and NASDAQ fined Vision for “failure to prevent and detect potentially manipulative trading activity”. [Pg. 28]
Amidst this slew of regulatory sanctions over failures relating to AML policies and manipulative trading, Freedom entered into its clearing agreement with Vision. Then, in what is unlikely to be a coincidence, Vision began effecting large quantities of trades in Freedom’s stock itself.
Per its website, one of Vision’s key businesses is clearing for “small and medium sized brokers/dealers.” In basic terms, that means it provides infrastructure for market participants to access the US securities market and settle trades.
A former Vision Financial Markets executive we spoke to told us that clearing was one of Vision’s “key” businesses as well as routing and executing trades. The former executive stated that Vision’s “biggest customer is an offshore firm, but it’s a firm that’s got ties back to Russian ownership”.
When asked if they meant Freedom, the former executive responded:
“Yeah, Freedom…Freedom Financial”
The former executive described in general terms the omnibus structure that Vision offers brokerage clients, like Freedom, which allow them to execute and clear trades. He stated clearly that Vision would not know who the end clients were.
“Yes. There’s only one account. That account could be one customer. It could be a thousand customers, it could be a million customers… So we don’t know the individual customers.”
The former Vision executive then went on to reflect on the lack of compliance at Vision and its inability to properly oversee the business:
“There was like one and a half people in compliance. You know, one [and a half] people, and I say half because somebody was doing two jobs… for that level of work and the business they’re doing, they […] didn’t have enough staff to do the job properly”
They felt Vision was willing to facilitate business like Freedom’s that other’s simply weren’t.
“The takeaway—and I talked about ‘dodgy’—is that Vision’s operating in areas that other firms don’t want to operate in. And maybe that works out or maybe at some point the regulators finally say ‘we’ve had enough of this’. So it’s a little bit dangerous, let’s put it that way.”
Beyond questions around high volumes of suspicious trading by tiny brokerages close to Freedom, part of the stock support may also be explained by an unusual and seemingly illegal practice by Freedom.
Freedom claims that a key competitive edge for its brokerage has been that its ability to secure IPO allocations from a secret hedge fund, as explained earlier.
FINRA Rule 5131 explicitly prohibits such quid pro quo allocations, stating:
“No member or person associated with a member may offer or threaten to withhold shares it allocates of a new issue as consideration or inducement for the receipt of compensation that is excessive in relation to the services provided by the member.” (Source: FINRA Rulebook)
Note that Freedom has a FINRA registered broker/dealer called “Freedom Capital Markets”, which would seemingly fall subject to those rules.
Potential legality of the arrangement aside, the number of U.S. IPOs has fallen sharply since 2021, dropping from 1,035 in 2021 to 181 in 2022. Ergo, the benefit to those clients buying Freedom’s stock for IPO access has eroded, along with support it has provided to the stock.
Freedom’s filings claim that part of its business strategy is to “Excel in governance, transparency and continuous investments in regulatory compliance” and to “strive[s] to be a trusted participant in the regulatory framework in each jurisdiction where we operate”. [Pg. 8]
Despite these claims, our research has found a litany of regulatory sanctions and red flags surrounding Freedom’s business. These issues go beyond the remarkable regulatory issues already noted earlier, such as Freedom’s sanctioning in Ukraine and the blacklisting of its key related party FFIN Belize in Kazakhstan.
The four entities have a combined 244 total penalties, resulting in 121 sanctions or other administrative penalties, totaling 160,082,585 tenge (U.S. ~$353,000).
While the fines are low, the nature of the infractions are revealing.
Among other issues, Freedom Finance JSC was penalized for issues “concerning counteraction to legalization (laundering) of income earned illegally, and terrorism financing in the part of the documentary recording and provision of information on transactions subject to financial monitoring”.
Freedom Finance JSC also paid fines for “inaccurate reporting on its activity”, and “the submission of unreliable, as well as incomplete reports”.
Freedom Finance Insurance paid fines for, among other things, “false financial statements and other types of reporting”.
Bank Freedom Finance KZ paid fines for “the ineffectiveness of the risk management and internal control system in the bank”.
Finally, Freedom Finance Life was sanctioned for, among other things, “compliance with accounting and financial reporting standards”, and, similar to Freedom Finance JSC, violations related to laundering of proceeds from crime and terrorist financing.
Freedom has been the subject of an undisclosed SEC investigation since at least October 26, 2021, according to a June 2023 report by Disclosure Insight, an independent research firm with more than two decades of experience using Freedom of Information Act (FOIA) requests to determine if companies are under active investigation.
Disclosure Insight noted that the SEC investigation was confirmed as ongoing in December 2022, saying:
“It strains credibility to imagine [Freedom’s] management still thinks its SEC probe is not material enough to warrant disclosure.”
One might think an ongoing SEC investigation and barring of Freedom’s audit partners would prompt the company to focus more closely on its internal controls. That doesn’t seem to be the case, however.
Freedom has restated its financials 4 times on the back of cash flow accounting discrepancies, has recast its annual financials in 6 separate years and was late in filing on 9 occasions, per SEC filings. The company’s recently-filed 2023 10-K was also months late. [1,2]
In addition, Freedom’s most recent annual report disclosed that its CEO and CFO have determined its disclosure controls and procedures were not effective:
“Based upon that evaluation, our principal executive officer and principal financial officer concluded that, as of March 31, 2023, due to the material weaknesses in our internal control over financial reporting described below, our disclosure controls and procedures were not effective.” [Pg. 164]
On June 5th, the SEC announced a major enforcement action against Binance, the largest crypto exchange in world. In its release, the SEC alleged that Binance and its founder brazenly operated an “extensive web of deception, conflicts of interest, lack of disclosure, and calculated evasion of the law.”
The SEC’s 136 page complaint includes damning evidence, showing, among other things, Binance’s CCO apparently admitting to operating an unlicensed securities exchange in the USA.
The complaint goes on to allege that Binance funds were commingled with outside entities tied to its founder, that an entity controlled by Binance’s founder wash traded on the platform, and that Binance misled investors. [Pg. 4] [Pg. 47] [Pg. 58]
Media outlets speculated that the severity of the SEC charges could lead to follow-on criminal charges.
When an enterprise is accused by the SEC of running an extensive web of deception and fraud, other companies regulated by the same authority might choose to avoid the enterprise at all costs.
Not so with Freedom. On June 21st, 16 days after the SEC filed charges, the founder of Binance tweeted an announcement about the launch of a digital asset platform in Kazakhstan, specifically highlighting new “local banking support” from Freedom Finance Bank.
All told, Freedom has exhibited a startling array of red flags relating to virtually every category of financial malfeasance worthy of investigation.
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 Mainly Kazakhstan, Kyrgyzstan, Uzbekistan and Ukraine.
 Turlov was a citizen of Russia and St. Kitts until mid-2022, when he announced – just months into the Russia-Ukraine war – he was transitioning to Kazakhstan residency. St. Kitts was described as the world’s “most secretive offshore [tax] haven” in a 2018 Guardian report.
 Maxim was ranked outside the top 20 per Bloomberg’s League Tables in 2022. The majority of its deals were less than $15 million in size in 2022.
 We calculated Freedom’s commission and fee income specifically from FFIN Belize and divided by total revenue.
 Igor Sechin, Rosneft and Russian Regional Development Bank were specifically sanctioned under the terms of U.S. executive orders originally issued in March 2014. Sechin was added to the sanctions list on April 28, 2014. Rosneft was hit with sanctions two-and-a-half months later on July 16, 2014. That July 2014 directive also included its subsidiary Russian Regional Development Bank. OFAC clarified that interpretation and specifically identified the Russian Regional Development Bank in later updates.
 The deal to purchase Okhabank from sanctioned Russian entities consummated in full in April 2016, when Freedom Holding, then a U.S.-listed public company, acquired the remaining 90.72% of shares and changed Okhabank’s name to Freedom Finance Bank.
 Executive Order 13662 issued on March 20, 2014 states “Sec. 4. The prohibitions in section 1 of this order include but are not limited to: (a) the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order;
 That same month, Turlov renounced his Russian passport and took on citizenship of Kazakhstan – strategic move allowing him to continue to travel freely after the EU imposed a ban on flights from Russia in February 2022 and a number of EU nations had imposed entry bans on Russians by September 2022.
 Readers can replicate this search by navigating to https://www.president.gov.ua/documents/7262022-44481, searching for Appendix 1 (Додаток 1), then searching for “Турлов Тімур Русланович”(Timur Turlov Ruslanovich)
 In July 2023, the channel had over 8,200 members (a sizable number when compared to Freedom’s disclosed “active accounts” of 56,000 as of December 2022). [Pg. 72]. It is unclear whether this is an official or unofficial channel of Freedom.
 Freedom had made ad-hoc related party disclosures dating back to July 2018 relating to FFIN Belize. For example, it paid modest private placement fees to FFIN Brokerage and made loans to it, per a 2018 Schedule 144a disclosure. [Pg. 30]
 For example, Charles Schwab dedicates a whole page of its 2022 annual report to precise details of what clients own and the growth in client accounts and assets. [Pg. 18] Plus 500 has separate line items for customer deposits and segregated client funds, per its 2022 annual report. [Pg. 127] Interactive Brokers has many different client line items and disclosures, including customer equity, customer margin assets, segregated cash in its 2022 annual report. [Pgs. 60, 86]
 The notion that FFIN Belize is issuing retail clients with derivatives based on US IPO allocations is corroborated by a leading financial information website in Russia, banki.ru. Per Crunchbase, banki.ru is the no.1 bank information website, according to Russia ratings.
 Another former employee also made their suspicions clear that there might not be real IPO allocations: “But my suspicion is that there is no actual IPO. Like there is no actual […] stock allocation, but you have some kind of derivatives. I don’t think that it’s a really actual allocation[…]I think that this is some kind of derivatives”
 By appointment is a specific trading term describing a security that has little liquidity on normal exchanges, requiring participants to search for liquidity on a block basis, usually with the help of an institutional broker.
 The full list of CUSIPs: BY6053478, BZ1147694, ZN2011270, ZN5458916, BZ4516036, ZL1827845, ZL4704645, ZJ8532765, BZ2785724, ZN2011288, ZN6509733, ZN7481940, BP2326828, BZ4185659, ZN7490800, BP2338849, BZ2786508, ZK0195766, ZJ8538242, ZN6514733, BP2335696, ZM5768696, BP2326786, ZN6519526, ZM5769991, BP2333519, BP2298167, BP2296336
 Per Bloomberg historical volume data as at 10 August 2023
 According to Fitch, the Kazakh Sustainability Fund had total debt of KZT1,012.5 billion, translated to around U.S. $2.2 billion. This compares to Freedom’s disclosed holdings as of December of U.S. $835 million.
 Accurate yield pricing was not available for 6 bond issues. We used Bloomberg field: “YLD_YTM_MID” as at 10 August 2023
 The following bonds with maturities between 2025 and 2032 had between 12.07-13.01% mid yield to maturity: BP2298167, BP2296336, BP2335696, BP2333519, BP2326786, BP2338849, per Bloomberg. BP2338849 yielded 12.07% as at 10 August 2023
 It is not exactly clear if Freedom has classified the Kazakh Sustainability Fund as sovereign or corporate debt. It trades on KASE an individual issuer yet is backed by the government.
 ECN stands for Electronic Communication Network, meaning the exchange
 We used the function BAS (brokerage activity summary) which collates data from the Nasdaq Exchange.
 To replicate this search, navigate to this link and search for the following Freedom entities: “Bank Freedom Finance Kazakhstan, JSC”, “Freedom Finance, JSC”, “Insurance Company Freedom Finance Insurance, JSC”, “Life Insurance Company Freedom Finance Life, JSC”. A fifth entity, Investment Company Freedom Finance, LLC, turned up no regulatory infractions.