Concept
Freedom Bank Kazakhstan JSC is the retail and commercial bank of Freedom Holding Corp., a Nasdaq-listed group (ticker FRHC) whose controlling shareholder, chairman and chief executive is Timur Turlov. The group bought Kassa Nova Bank JSC, a Kazakhstan consumer bank with ten branches, in December 2020 and renamed it Freedom Bank Kazakhstan in May 2024 (Freedom Holding annual report on Form 10-K for the year to 31 March 2026).
Scale explains the bank's character. For the fiscal year to 31 March 2026 the group reported total net revenue of $2,191.3 million and net income of $153.3 million, and total assets rose to $13.2 billion from $9.9 billion a year earlier. Its banking segment counted 5,026,000 customers at 31 March 2026, against 2,515,000 a year earlier, and the group estimates that about 84% of its revenue came from Kazakhstan (same 10-K). This is a fast-growing universal bank for the mass and affluent market, not a discreet private bank.
Regulation
- Agency for Regulation and Development of the Financial Market (ARDFM): banking licence and prudential supervision.
- National Bank of Kazakhstan: central bank and monetary policy.
- Kazakhstan Deposit Insurance Fund (KDIF): tiered guarantee of deposits, accounts and cards at member banks.
- Freedom Holding Corp.: files annual and quarterly reports with the US Securities and Exchange Commission as a Nasdaq-listed issuer.
What it offers
The group describes Freedom Bank as a digital retail and commercial bank offering deposits, multi-currency payment cards, consumer and SME loans, payment and acquiring services (10-K). Banking, insurance, brokerage and lifestyle services (ticketing, travel, grocery delivery through Arbuz) are packaged in the Freedom SuperApp, launched in April 2024, which had 5.2 million registered users by March 2026.
Brokerage is a separate legal product. Accounts at Freedom Broker give access to exchange-traded securities, and the group reported 858,000 brokerage customer accounts at 31 March 2026. Money in a brokerage account is an investment asset, not a bank deposit, so the KDIF guarantee does not follow it; see international brokerage accounts.
Account opening for non-residents
Freedom Bank states that it does not open cards remotely for foreign citizens: a non-resident Deposit Card is issued only in person at a Freedom Bank branch in Kazakhstan, against an identity document, a Kazakhstan-registered individual identification number (IIN) and a valid phone number; the IIN itself is obtained by the individual at a public service centre, and cards are delivered only within Kazakhstan (Freedom Bank notice of 15.08.2024).
Regulation sets the frame for the rest. Under the ARDFM requirements for banks' AML internal-control rules (Resolution No. 18, as restated by Resolution No. 74 of 20.04.2026), a non-resident whom the bank rates as high risk for money laundering or fraud cannot open a relationship or receive a card remotely or through a representative, may hold only one payment card, and gets a debit card valid for no more than 12 calendar months, with monthly biometric re-confirmation (ARDFM Requirements, para. 27). The same requirements provide a separate biometric route for non-residents using Kazakhstan's e-Residency services.
Key considerations
- A listed parent is a reporting backstop, not Western supervision. The bank answers to Kazakhstani regulators.
- Regulatory overhang at the parent. Since 2021 the company and some officers have received subpoenas and requests from the SEC's Division of Enforcement; on 11 March 2026 the company and Timur Turlov received a Wells Notice stating that SEC staff had made a preliminary determination to recommend a civil enforcement action. A Wells Notice is not a charge or a finding of wrongdoing (10-K).
- Russia exposure. The group divested its Russian subsidiaries in February 2023, but says its non-US brokerage and banking customers still include non-sanctioned Russian persons (same 10-K). Expect enhanced due diligence on clients with Russian links.
- Currency risk. Balances in tenge carry exchange-rate risk against the dollar and euro; see multi-currency accounts and FX.
- Not a private bank. There is no custody-and-advice model of the Swiss or Singapore kind.
Where Freedom Bank Kazakhstan fits
- Everyday banking, cards and tenge settlement for residents and people relocating to Kazakhstan.
- A banking partner for clients with an AIFC company or other genuine ties to Kazakhstan.
- Existing Freedom Broker clients who want banking and brokerage in one app.
- Clients with a documented source of funds who accept an in-person visit.
Where it does not fit
- UHNW wealth management, custody and fiduciary services: Swiss, Singapore and Hong Kong private banks are specialised for that.
- Large long-term balances in tenge without a currency plan.
- Remote onboarding for non-residents.
- A single-bank home for all liquid wealth, given the parent's open SEC matter.
The wider market for non-residents is compared in Kazakhstan banks for non-residents.
Reporting and information exchange
Kazakhstan committed to first automatic exchanges of financial account information under the Common Reporting Standard by 2021 (OECD, AEOI commitments). Whether a given balance reaches a given country depends on the account type, the holder's tax residence and an active exchange relationship; see the CRS overview. Russian tax residents also have their own notification and cash-flow reporting duties for foreign accounts (reporting foreign accounts to the Russian tax authority).
Q/A
Protection of money
Does KDIF guarantee any KZT 20 million held at Freedom Bank?
No. The limits differ by product: KZT 20 million for tenge savings deposits, KZT 10 million for tenge cards, accounts and other deposits, and KZT 5 million for foreign-currency cards, accounts and deposits. Total compensation at one bank is capped at KZT 20 million, and each sub-limit still applies.
Does KDIF cover money in a Freedom Broker account?
No. KDIF guarantees deposits, accounts and payment cards at member banks. A brokerage account is an investment product at a separate company, so the protection has to be read from the legal product, not the shared Freedom brand.
Status and access
Does the Nasdaq listing make Freedom Bank an American bank?
No. Freedom Holding Corp. reports to the SEC as a US-listed issuer, but Freedom Bank Kazakhstan is a Kazakhstani bank under ARDFM licence No. 1.1.551.129 of 7 July 2026.
Can a non-resident open a Freedom Bank card remotely?
Not through ordinary onboarding. The bank issues non-resident cards only in person at a branch in Kazakhstan, with an IIN and a local phone number; high-risk non-residents are also barred by regulation from remote card issue.
Is the SEC investigation of the parent resolved?
No. In March 2026 the company and its chief executive received a Wells Notice. It signals a possible civil enforcement recommendation, not a charge, and the outcome is open.