Freedom Bank: The Architects of Trust

A decade ago, the prevailing belief was that technology companies would disrupt banks, fintechs would unbundle financial services, and consumers would abandon traditional institutions in favour of digital-first alternatives built around convenience and user experience.

Those first two predictions proved correct. The third? Not so much.

So, as artificial intelligence (AI) reshapes digital experiences, telecom operators expand into financial services and technology platforms continue to move into payments, lending
and commerce, a new question is emerging. Why, after all this time, is it still so hard to prise customers away from legacy banks? Could it be they hold on to one thing none of these challengers has yet been able to replicate? Trust.

That’s what one of the most closely watched financial institutions to emerge from Central Asia's rapidly evolving fintech landscape believes, and it’s is focussed on leveraging it.

Part of Freedom Holding Corp’s ecosystem of banking, brokerage, insurance, telecommunications and lifestyle services, Freedom Bank Kazakhstan has spent the past several years building a superapp with a fully regulated bank at its core. In March this year, it received its first Moody's rating.

Freedom Bank’s story is inseparable from that of its billionaire founder Timur Turlov. His original vision centred not on banking, but on giving investors across Kazakhstan and Central Asia access to global capital markets. Unlike many banks, which begin with current accounts, deposits, then lending before expanding into investment products, Freedom's journey ran in reverse. Then it leapt across verticals as Freedom Group built its own telecommunications company and data storage centres.

As a result, Freedom increasingly thinks less like a bank and more like a platform company built around financial participation. Speaking to executives leading that platform now, it becomes clear they are no longer talking about building a better banking app; they are redefining the purpose of a bank.

“A modern bank is no longer just a place to store money or obtain loans. It is becoming a space of digital trust,” says Aidos Zhumagulov, CEO of Freedom Bank Kazakhstan.

That challenges many of the assumptions that have shaped fintech thinking over the last decade. For years, technology platforms have been viewed as the natural successors to traditional financial institutions. They have the scale, the data, the engagement and the infrastructure to move into financial services.

Freedom sees the future differently. Its leadership believes that it’s the banks that occupy a uniquely powerful position. And that’s  because they already sit at the intersection of identity, compliance, payments, security and trust.

In other words, banks may not simply survive the platform era – they may be uniquely positioned to define it.

The unlikely fintech laboratory Freedom’s origins lie in a market that many international observers still underestimate. When people think of fintech innovation, they usually skip to Silicon Valley, London or Singapore. Kazakhstan rarely makes the list. Yet, according to Zhumagulov, the country’s digital transformation
has created unusually fertile conditions for innovation.

Government services have become increasingly digitised. Remote identification, Cloud-based digital signatures and unified identification systems have made it possible for citizens to access both public and private services remotely.

At the same time, Kazakhstan has developed one of the region's most competitive banking sectors, pushing institutions to innovate aggressively around digital experiences and ecosystem development. But market conditions alone do not explain Freedom Bank’s growth.

“For Freedom specifically, our approach is that we are not building just a standalone bank, broker, or insurance business,” says Zhumagulov. “We are building an ecosystem that becomes part of our customers’ everyday life.”

While many financial institutions have attempted to bolt additional services onto core banking products, Freedom’s strategy has instead been to build banking around daily life, whether that’s buying an air ticket or groceries, investing for retirement or insuring your car.

As that platform has evolved, the boundaries between verticals began to disappear. Banking overlapped with lifestyle services, telecommunications intersected with payments, and financial services increasingly converged with commerce, mobility and media.Freedom didn’t try to defend those boundaries, but to erase them, to give customers one entry point to a wide range of facilities. But still, crucially, all enabled by the bank.

"We arrived at the idea of a unified interface where a user could both apply for a mortgage and order groceries within the same ecosystem,” explains Zhumagulov. “We never wanted to be just a financial intermediary.

“Traditionally, banks positioned themselves as institutions that collect deposits and issue loans,” he continues. “But in that model, customer interaction points happen relatively rarely.”

With this model, the more frequently customers engage, the stronger the banking relationship becomes. The company does not see itself as a participant within an ecosystem. It sees itself as the organisation designing it.

“It’s regulated as a bank, but conceptually, it is the core of an ecosystem,” says Zhumagulov. “And more than that, we are its architects and builders.”

Banking as a trust platform

Freedom believes the next generation of digital ecosystems will be built around trusted identities rather than individual products. In a sense, it’s answered the question that has bugged the industry ever since fintech began focussing on driving friction from every customer interaction: once those problems were solved and financial services disappeared into the background, how did institutions remain relevant?

Banks have the advantage, says Freedom, because, unlike social media platforms, retailers and many fintech challengers, they already know who their customers are. They perform KYC checks, hold verified identities, operate under strict regulation and possess decades of experience in managing risk and sensitive information. That, it says, makes banks uniquely positioned to become digital infrastructure providers. Not because customers want more banking, but because they want fewer barriers between different parts of their lives.

Banking disappears

In this scenario, says Vyacheslav Kim, CEO of Freedom SuperApp and Executive Director of Freedom Bank, ‘the financial functionality itself will remain. What will change is the way people interact with the bank’.

Consumers no longer separate financial activity from everyday activity. Travel, shopping, healthcare, travel and entertainment all eventually involve payments, identity verification or financial transactions.

"This is why banking is gradually becoming not a separate destination, but an infrastructure layer inside everyday digital behaviour,” Kim adds.

Freedom SuperApp’s goal is not to create a catalogue of products, but to create a seamless environment where customers move effortlessly between different life scenarios without feeling they are switching applications or providers. The customer is not consciously visiting a banking service – they are buying a ticket, ordering groceries, paying for parking or booking a journey – but the bank at the centre always facilitates the final step.

The resulting ‘platform’ increasingly resembles bank-driven infrastructure.

From consumer to participant

Perhaps the most unusual aspect of Freedom’s strategy, though, has nothing to do with technology, but with who owns this future.

Most digital platforms are built around consumption. The more customers buy, click and transact, the more valuable the platform becomes, and the more the provider values them and rewards them with more incentives to spend or save. Freedom believes that model is incomplete.

“In my view, one of the key problems of the modern financial world is that most companies build their strategies around consumption,” says Zhumagulov. “We decided to rethink that philosophy entirely.”

What it came up with is an ETN (exchange-traded note)-based cashback programme, which represents one of the most ambitious attempts to redesign customer incentives in financial services. Rather than rewarding spending with points or discounts, the programme gives clients shares in Freedom Holding Corp., which is listed on NASDAQ. In one year, more than three million customers benefitted, while Freedom Holdings’ shares rose more than 200 per cent.

The programme is designed to encourage saving and investing, redefining the relationship between customer and institution and encouraging personal financial resilience and wealth-building. The bank doesn’t just give consumers’ confidence, it gives them
a stake in the business’s success.

"Our goal is to build an ecosystem around customer participation in the growth of the platform itself," says Zhumagulov. “In this structure, the customer is no longer simply a user of services, but, to some extent, becomes a participant in the ecosystem's growth.”

It’s a very different relationship that’s rooted in ownership and long-term reward. And, for a generation of banks struggling with commoditisation, it raises a fascinating question: can ownership become the ultimate loyalty mechanism, a modern version of mutuality, which has stood the test of centuries?

Competing with everyone

If Freedom's vision of banking’s future proves correct, the competition may look very different from that of the past. Banks will not only compete with other banks, but also with telecom operators, AI companies, technology platforms and anyone capable of becoming the trusted interface through which customers manage their lives. Already, Paytm in India, Grab and Gojek in South East Asia, Alibaba in China and KakaoTalk in South Korea are demonstrating how the line between banking and lifestyle is becoming blurred.

In Europe, UK-born neobank Revolut has spent years pursuing its own superapp ambitions and recently expanded into mobile services, allowing customers to purchase calls, data and SIM packages directly through its banking app. Monzo is moving in the same direction. Its forthcoming Monzo Mobile proposition extends the customer relationship beyond banking and into connectivity, rewarding customers with lower tariffs the longer they have the service.

Telecom operators are approaching the opportunity from the opposite direction. Saudi Telecom Company has evolved from
wallet-based services into full banking, while across Africa telecom groups have spent years showing how communications infrastructure can become a gateway to financial services.

In the Freedom ecosystem, too, the convergence of finance and connectivity is already visible. Through Freedom Telecom, the group is investing in telecommunications infrastructure designed to support digital services and financial ecosystems.

“I think future competition can come from any direction,” says Kim. “The real question is who will have enough courage to change the traditional model, launch new products quickly, and build the customer experience differently.”

Many banks possess the trust, licences and infrastructure needed to build powerful ecosystems – what they often lack is the willingness to rethink their role. This is why Freedom’s story has attracted attention far beyond Kazakhstan. The company is testing a hypothesis about the future shape of financial services. Can a bank become a platform? Can a platform create investors instead of consumers? Can trust become a competitive advantage in a world increasingly dominated by algorithms and AI? And can a market often viewed as peripheral become a proving ground for ideas that eventually spread globally?

Freedom has already begun exporting its banking infrastructure, technology capabilities and ecosystem approach into new market. Its European arm, Freedom24, which serves around 600,000 clients in Europe, applied for a banking licence in France in June, with a promise to invest €500million over the next five years in developing a digital bank and building digital infrastructure. Earlier this year, the Group announced it had taken a 99.32 per cent stake in Turkish Bank A.S., having already gained a full licence in Tajikistan in 2024.

It’s testing its theory that if banking becomes infrastructure, AI becomes an interface and ecosystems become the dominant way consumers interact with digital services, the winners may not be those with the best individual products, most if not all of which, will inevitably will be powered by AI.

Like every major financial institution, Freedom is investing heavily in AI-powered experience, but its executives take a notably measured view of the technology.

“I believe AI will become a very important interface for banking and financial services, but I do not think it will fully and quickly replace the classic interface,” says Kim.

In fact, Freedom sees AI as an enhancement rather than a replacement. "The future is not about the screen disappearing and only AI remaining,” he continues. "The future is a combination of a smart AI interface, a strong classic interface, and a human being who remains in control of key actions.”

The next generation of banking

Securing Moody’s recognition was an important milestone for Freedom, but the future of banking extends far beyond ratings, customer numbers or product launches.

As digital ecosystems increasingly converge around payments, identity, commerce, communications and AI, an even more important measure will be who is trusted to own the customer relationship.

Freedom firmly believes that, even as financial services become invisible to the consumer, that is still the bank. At least, the bank that’s bold enough to be the architecture of its own future.