[Form 4] Freedom Holding Corp. Insider Trading Activity

Rhea-AI Filing Summary

Amber Williams, a director of Freedom Holding Corp. (FRHC), was awarded and vested 626 restricted shares of the company's common stock on 09/15/2025 under the 2019 Equity Incentive Plan. The award was granted subject to applicable vesting conditions, including continuous service and market price conditions tied to the company's common shares, and the filing reports that vesting occurred on the grant date. Following the transaction, Ms. Williams beneficially owns 626 shares directly.

Positive

• 626 restricted shares were awarded and reported as vested to Director Amber Williams on 09/15/2025
• Transaction reported under the Company 2019 Equity Incentive Plan, demonstrating use of established compensation framework
• Form 4 discloses vesting conditions (continuous service and market price conditions) and confirms vesting occurred

Negative

• None.

Insights

Corporate Governance Expert

TL;DR: Director received and vested 626 restricted shares immediately under the equity plan, aligning compensation with shareholder value.

The Form 4 discloses a routine equity award to a director under the company’s 2019 Equity Incentive Plan. The grant and reported vesting on the same date indicate either time- and performance-based conditions were satisfied concurrently or administrative reporting reflects an immediate vesting event. The size of the award (626 shares) appears modest in absolute terms and likely immaterial to overall outstanding shares. This disclosure is standard for insider compensation transparency and does not, by itself, signal governance concerns.

Securities Compliance Analyst

TL;DR: Filing documents a compliant Section 16 report of an equity award and vesting by a reporting director on 09/15/2025.

The Form 4 meets Section 16 reporting requirements by identifying the reporting person, transaction date, security type, transaction code (A for acquisition), amount (626 shares), and that the shares vested under plan terms. The explanation clarifies vesting tied to continuous service and market price conditions. There is no indication of sales, option exercises, or derivative activity. From a compliance standpoint, the filing is complete and routine.

SEC Form 4

FORM 4

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
or Section 30(h) of the Investment Company Act of 1940

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

1. Name and Address of Reporting Person^*

Williams Amber

(Last) (First) (Middle)

ESENTAI TOWER BC, FLOOR 7

77/7 AL FARABI AVE

(Street)

ALMATY 1P 050040

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
Freedom Holding Corp. [ FRHC ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
	Officer (give title below)		Other (specify below)

3. Date of Earliest Transaction (Month/Day/Year)
09/15/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	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	09/15/2025		A		626(1)	A	$0	626	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 (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	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 (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (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: 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

Explanation of Responses:

1. Ms. Williams was awarded 626 restricted shares of common stock of Freedom Holding Corp. (the "Company") on September 15, 2025, under the Company 2019 Equity Incentive Plan. 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, vesting of the shares occurred on September 15, 2025.

	/s/ Amber Williams	09/15/2025
	** Signature of Reporting Person	Date
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).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What transaction did Amber Williams report on Form 4 for FRHC?

The Form 4 reports an acquisition and vesting of 626 restricted shares of Freedom Holding Corp. common stock on 09/15/2025.

Under which plan were the 626 restricted shares awarded?

The shares were awarded under the company’s 2019 Equity Incentive Plan.

Did the restricted shares vest immediately for Amber Williams?

Yes, the filing states that, assuming satisfaction of vesting conditions, vesting occurred on 09/15/2025.

What vesting conditions are noted in the Form 4?

The Form 4 specifies continuous service and market price conditions tied to the company’s common shares as applicable vesting conditions.

How many shares does Amber Williams beneficially own after the reported transaction?

Following the reported transaction, Amber Williams beneficially owns 626 shares.