Statement from FREEDOM FINANCE UKRAINE on unanticipated inclusion on the National Security and Defense Council of Ukraine (NSDC) sanctioned list

October 21, 2022 – We were stunned to learn today that FREEDOM FINANCE UKRAINE LLC was included on the National Security and Defense Council of Ukraine sanctions list, which included more than 2,500 companies and individuals, and was released on October 19, 2022.  We believe that the inclusion of the company on this list is erroneous.

As a result of being erroneously included on this list, FREEDOM FINANCE UKRAINE LLC is taking all necessary, appropriate, and reasonable measures to resolve this situation. The company has submitted a package of documents to the responsible state bodies of Ukraine to appeal the decision and will seek the removal of sanctions from FREEDOM FINANCE UKRAINE LLC in the manner established by legislation.

FREEDOM FINANCE UKRAINE LLC has a transparent and clear ownership structure, in which there is no Russian ownership, assets or beneficiaries with Russian citizenship.

In addition, Freedom Holding Corp. previously announced it has entered into an agreement for and has announced (via 8-K and press release) the sale of its two only Russian subsidiaries.  Its CEO, Timur Turlov, has renounced his Russian citizenship and is now a citizen of Kazakhstan.  In addition, FREEDOM FINANCE UKRAINE LLC and its senior management have contributed millions of dollars to Ukrainian humanitarian causes.

The assets of FREEDOM FINANCE UKRAINE LLC comprise less than 0.3% of the total consolidated assets of Freedom Holding Corp.

FREEDOM FINANCE UKRAINE LLC remains committed to transparency. We believe the imposition of sanctions on the company is an error and will be resolved quickly. Freedom Holding Corp. will honor all of the obligations to customers and counterparties of FREEDOM FINANCE UKRAINE during this period.