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March 29, 2024
Evgeniy Ler
Chief Financial Officer
Freedom Holding Corp.
“Esentai Tower” BC, Floor 7
77/7 Al Farabi Ave
Almaty, Kazakhstan 50040
Re:Freedom Holding Corp.
Form 10-K for the Fiscal Year Ended March 31, 2023
File No. 001-33034
Dear Evgeniy Ler:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2023
Net Capital and Capital Requirements, page 78
1.Please provide draft disclosure to be included in future filings to expand your discussion
of capital requirements and dividend restrictions, if any. Refer to ASC 944-505-50 and
948-10-50.
Notes to Audited Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Derecognition of Financial Assets, page 107
2.We note your disclosure in your recent balance sheets of $494.5 million, $440.8 million,
and $6.4 million for liabilities arising from continuing involvement, and the related loan
principal, as of December 31, 2023, March 31, 2023, and March 31, 2022.  We further
note disclosure in Note 2 on page 107 regarding your accounting policy for derecognition
of financial assets.  Please provide the following:

 FirstName LastNameEvgeniy Ler
 Comapany NameFreedom Holding Corp.
 March 29, 2024 Page 2
 FirstName LastName
Evgeniy Ler
Freedom Holding Corp.
March 29, 2024
Page 2
•We note your disclosure in Note 8 on page 130 of digital mortgage loans you issue to
borrowers on behalf of JSC Kazakhstan Sustainability Fund to borrowers under
the "7-20-25" state mortgage program, where you continue to recognize the loans as
you determined you retain control over the loan claim rights transferred to the
Program Operator as the right are issued with recourse for uncollectible amounts, you
retain some interest, and you continue to service the loans after sale.  Please respond
to the following and provide us proposed disclosure to revise your accounting policy
for financial asset derecognition in future filings where appropriate:oPlease tell us how you determined your continuing involvement with the
transferred assets, detailing any guidance you considered. Refer to ASC 860-10-
55-79B.
oTell us how you considered whether you met the condition of ASC 860-10-40-5
regarding the surrender of financial asset control by the transferor.
oPlease revise to clarify how the transfer of financial assets affects your financial
position, financial performance, and cash flows. Refer to ASC 860-10-50-3(d).
oRevise to disclose your consideration of similar transfer aggregation. Refer to
ASC 860-10-50-4A.
•Tell us if you have any continuing involvement in your recently discontinued Russian
segment, and if so, how you considered the guidance in ASC 205-20-50-4.
Note 22 - Net Interest Income/Expense, page 143
3.Please provide us your analysis of net interest income in accordance with Regulation S-K,
Item 1402.a. and b. Include in your response draft disclosure to be included in
management's discussion and analysis in future filings.
             In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Rolf Sundwall at 202-551-3105 or Bonnie Baynes at 202-551-4924 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets