Sec Form 4 Filing - Lukyanov Sergey @ Freedom Holding Corp. - 2025-02-14

FORM 4 Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person Lukyanov Sergey 2. Issuer Name and Ticker or Trading Symbol Freedom Holding Corp. [ FRHC] 5. Relationship of Reporting Person(s) to Issuer (Check all applicable) _____ Director _____ 10% Owner X __ Officer (give title below) _____ Other (specify below) *See Remarks (Last) (First) (Middle) ESENTAI TOWER BC, FLOOR 7, 77/7 AL FARABI AVE 3. Date of Earliest Transaction (MM/DD/YY) 02/14/2025 (Street) ALMATY, 1P050040 4. If Amendment, Date Original Filed (MM/DD/YY) 6. Individual or Joint/Group Filing (Check Applicable Line) __ X __ Form filed by One Reporting Person _____ Form filed by More than One Reporting Person (City) (State) (Zip)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned 1.Title of Security (Instr. 3) 2. Transaction Date (MM/DD/YY) 2A. Deemed Execution Date, if any (MM/DD/YY) 3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4) Code V Amount (A) or (D) Price Common Stock 02/14/2025 S 2,901 D $ 160.29 ( 2 ) 124,800 ( 1 ) D Common Stock 02/18/2025 S 1,958 D $ 160.53 ( 3 ) 122,842 ( 1 ) D Common Stock 02/19/2025 S 2,042 D $ 157 120,800 ( 1 ) D

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned ( e.g. , puts, calls, warrants, options, convertible securities) 1. Title of Derivative Security (Instr. 3) 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (MM/DD/YY) 3A. Deemed Execution Date, if any (MM/DD/YY) 4. Transaction Code (Instr. 8) 5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4, and 5) 6. Date Exercisable and Expiration Date (MM/DD/YY) 7. Title and Amount of Underlying Securities (Instr. 3 and 4) 8. Price of Derivative Security (Instr. 5) 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4) 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4) Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares

Reporting Owners Reporting Owner Name / Address Relationships Director 10% Owner Officer Other Lukyanov Sergey ESENTAI TOWER BC, FLOOR 7 77/7 AL FARABI AVE ALMATY, 1P050040 *See Remarks Signatures /s/ Sergey Lukyanov 02/19/2025 Signature of Reporting Person Date

Explanation of Responses:

( 1 )Mr. Lukyanov was awarded 106,000 restricted shares of common stock of Freedom Holding Corp. (the "Company") under the Company 2019 Equity Incentive Plan pursuant to that certain Restricted Stock Award Agreement entered into as of May 18, 2021, by and between the Company and Mr. Lukyanov (the "Agreement"). Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, 21,200 shares will vest annually beginning May 18, 2022 through May 18, 2026. Mr. Lukyanov's previously filed Form 3 inadvertently omitted the unvested restricted shares of common stock from Mr. Lukyanov's beneficially owned securities, which are now reflected in this Form 4. ( 2 )Reflects the weighted average price of sales on February 14, 2025. The shares were sold in multiple transactions at prices ranging from $160.20 to $160.51, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range. ( 3 )Reflects the weighted average price of sales on February 18, 2025. The shares were sold in multiple transactions at prices ranging from $160.25 to $160.80, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

Remarks: Chairman of the Management Board of Freedom Finance JSC and Chairman of the Board of Freedom Finance Global PLC

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.

* If the form is filed by more than one reporting person, see Instruction 4(b)(v).

** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).

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