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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:
 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:
                o   Please tell us how you determined your continuing
involvement with the
                    transferred assets, detailing any guidance you considered.
Refer to ASC 860-10-
                    55-79B.
                o   Tell 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.
                o   Please 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).
                o   Revise 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.



FirstName LastNameEvgeniy Ler                                    Sincerely,
Comapany NameFreedom Holding Corp.
                                                                 Division of
Corporation Finance
March 29, 2024 Page 2                                            Office of
Crypto Assets
FirstName LastName