Against the backdrop of this voluminous publication, shares of the fintech company  AO Kaspi kz  fell by 23% on the American NASDAQ stock exchange  , which allowed the people behind  Culper Research  to make money on short stock exchange positions - for this purpose, the people behind  Culper Research  pre-purchase shares of the company about which the investigation will be published, with "leverage" - that is, on credit, and sell them before the release of their investigation at the current stock exchange price; later, when the shares fall in value, a reverse purchase is made, ensuring the return of the debt and allowing you to make money on the difference in price. Let us recall that earlier, in 2023, in a similar way, the American research company  Hindenburg Research  carried out a "short" of the largest investment holding in the post-Soviet space -  Freedom Holding Corp.,  owned by the Kazakhstani billionaire of Russian origin  Timur Turlov. At that time, Hindenburg Research   sources  claimed that  Freedom Holding Corp.  in 2022 was mainly engaged in the withdrawal of frozen or blocked assets of legal entities and individuals from Russia, while the commission for bypassing sanctions restrictions was about 15% and was used to manipulate the market in order to maintain stable trading volumes and prices for  Freedom Holding Corp. shares. As a result,  Freedom Holding Corp.  shares fell  by 9%  from their previous market value during trading on the American NASDAQ stock exchange, but the investigative company  Culper Research,  unlike  Hindenburg Research,  is more famous and authoritative, and was previously even recognized as one of the five best short sellers in the United States; as a result, the voluminous publication on the activities of the fintech company  AO "Kaspi kz"  turned out to be much more extensive, detailed and professional than previously by  "Hindenburg Research", and  as a result, the fall in the securities of the fintech company of  Kim  and  Lomtadze  turned out to be more significant than the fall in the securities of the investment holding  of Turlov. It is obvious that in the near future the fintech company  AO "Kaspi kz",  owned by the Kazakh oligarchs  Vyacheslav Kim  and  Mikhail Lomtadze, 









a certain amount of effort will be required, including significant costs in the field of consulting, as well as PR, to reduce the damage caused to the capitalization and reputation of the fintech company, and to return the previously existing positions on the American stock exchange NASDAQ.

Formally, the fintech company  of Kim  and  Lomtadze  has already issued a refutation of the data contained in a voluminous publication of the American investigative company  "Culper Research" , which is engaged in the sale of so-called "short positions" on the stock market and specializes in investigations in the field of financial crimes and the search for hidden problems in large public companies, but the refutation itself does not affect the entire volume of data published by  "Culper Research"  and compromising the fintech company  of Kim  and  Lomtadze.

Thus, the refutation only states that the fintech company is a regulated public company, whose shares have been traded on the London Stock Exchange (LSE) since 2020, and on the American stock exchange NASDAQ since 2024, in connection with which  Kim  and  Lomtadze  regularly disclose information in accordance with regulatory requirements and have undergone extensive legal verification. At the same time, the issued refutation, due to its lack of content, was published mainly in the Kazakhstani media and spread in the Kazakhstani information space, which is under the partial control of the beneficiaries of the fintech company  AO "Kaspi kz"  -  Kim  and  Lomtadze,  and went unnoticed by the US information space.

Let us recall that earlier the Kazakhstani oligarchs behind the fintech company  AO "Kaspi kz"  were repeatedly caught in direct shadow influence on the socio-political space of Kazakhstan through Kazakhstani Internet and individual Kazakhstani journalists and representatives of the blogosphere, whose loyalty is generously paid by the PR department of the fintech company itself.

At the same time, it is noteworthy that of the entire volume of data published by  "Culper Research"  and compromising the fintech company  of Kim  and  Lomtadze , the most important for the stock market were the accusations that the fintech company  AO "Kaspi kz"  bypasses the sanctions imposed on Russia, which means that during the next round of station pressure from the United States, the fintech company  AO "Kaspi kz" and its beneficiaries risk falling under the so-called "secondary sanctions" from the United States. This information became key for investors and the stock market and, in fact, led to the fact that the shares of the fintech company  AO "Kaspi kz"  collapsed on the American stock exchange NASDAQ  by 23%.

However, in reality, the accusations that the fintech company  AO "Kaspi kz"  is bypassing the sanctions imposed on Russia can only be taken seriously by investors from the United States, for whom information about this, coupled with allegations that the fintech company  AO "Kaspi kz"  could hide this from the American regulator, are critical, since it generates mistrust in the activities of a public company and creates unnecessary risks.


Meanwhile, the voluminous publication of the American investigative company  Culper Research  contains about thirty pages and in addition to the accusations concerning the connections of the fintech company  AO Kaspi kz  with Russia, which interested investors from the USA, this voluminous publication also contains other information that may be of interest primarily to investors from Kazakhstan, as well as other jurisdictions.

Thus, in particular, the voluminous publication directly indicates that the fintech company  AO "Kaspi kz"  could have participated in the laundering of funds of the nephew of the first president of Kazakhstan  Nursultan Nazarbayev  -  Kairat Satybaldy,  and also indicates the connection of the fintech company  AO "Kaspi kz"  and its beneficiaries, Kazakhstani oligarchs  Vyacheslav Kim  and  Mikhail Lomtadze , with other representatives of the political and business elite of the so-called "old Kazakhstan" - Kazakhstani oligarch  Kenges Rakishev , who is the son-in-law of the Secretary General  of the Collective Security Treaty Organization (CSTO) Imangali Tasmagambetov , the former head of  the National Security Committee  of Kazakhstan  Karim Massimov , accused of treason, attempted violent seizure of power and abuse of power and official authority, and one of the richest businessmen of Kazakhstan  Kairat Boranbayev,  who is currently under investigation by the Financial Monitoring Agency of Kazakhstan and who, as part of voluntary cooperation with the investigation, turned over funds  in the amount of 134.5 billion tenge in favor of the Kazakh state.

In other words, the American investigative company  Culper Research  is confident not only that the fintech company  AO Kaspi kz systematically misled American investors and US regulators, such as the Securities and Exchange Commission  (SEC),  in terms of cooperation with Russia, Russian investors, partners and counterparties, as well as Russian businesses that made a significant contribution to the development of the fintech company  AO Kaspi kz,  but also in the fact that the fintech company  AO Kaspi kz  and its beneficiaries in the person of the Kazakh oligarchs  Kim  and  Lomtadze  are closely associated with the Kazakh kleptocortia, currently being prosecuted by the official authorities of Kazakhstan for crimes of a general criminal and corruption nature.


The accusations that the fintech company  AO Kaspi kz  is bypassing sanctions imposed on Russia, in a voluminous publication by the American investigative company  Culper Research,  are based on the following: despite the fact that the fintech company  AO Kaspi kz  does not disclose information on the volume of payments to Russia and other non-residents, according to data from the National Bank of Kazakhstan, from the end of 2021 to the second quarter of 2024, non-resident deposits in Kazakhstani banks have sharply increased  by 338%  and are estimated at  3.3 trillion tenge,  and the fintech company  AO Kaspi kz  has made a significant contribution to this growth, as evidenced, in particular, by data found in the public domain.

In addition, data found by the investigative company  Culper Research  in the public domain indicate that the fintech company  AO Kaspi kz  continues to benefit from the inflow of funds from Russia and makes payments through the Russian bank  PAO Bank VTB. However, the interaction of the fintech company
AO Kaspi kz with the Russian side is by no means limited
to the benefit from the inflow of funds from Russia   . For example, among other things, the fintech company  AO Kaspi kz  uses the Russian PR agency  Contextual Technologies,  which is associated with the Russian official authorities and through this Russian PR agency influences the socio-political space of Kazakhstan. It is noteworthy that, among other things, the publication of Culper Research  also indicates that before the listing on the London Stock Exchange (LSE), after which the fintech company  JSC Kaspi kz  became the most expensive public company in Kazakhstan, one of the main shareholders of  JSC Kaspi Bank  was the nephew of the first president of Kazakhstan  Nursultan Nazarbayev  -  Kairat Satybaldy,

 who owned  30% of the shares.  And despite the fact that the fintech company  AO "Kaspi kz"  and its beneficiaries, Kazakhstani oligarchs  Vyacheslav Kim  and  Mikhail Lomtadze, currently  deny any connection with  Satybaldy,  it is obvious that without this connection the fintech company would not have been able to increase its revenue due to funds from Russia, since before meeting  Satybaldy ,  neither  Kim  nor  Lomtadze  had any connections in Russia, and therefore would not have been able to ultimately earn money on the flight from Russia of funds belonging to certain representatives of the Russian political and business elite immediately after the start of the Russian-Ukrainian conflict.

Moreover, from a voluminous publication by the American investigative company  Culper Research  it follows that the actions taken by the Kazakh oligarchs  Kim  and  Lomtadze before the listing on the London Stock Exchange (LSE) could have been aimed not at the final exclusion  of Satybaldy  from the list of shareholders, but at concealing his real share in the fintech company  AO Kaspi kz , with the aim of making the initial public offering of shares of the fintech company more attractive to foreign investors, deliberately misleading such investors.

Also, the connection of the fintech company  AO "Kaspi kz"  with the Russian side, as follows from the publication of  "Culper Research",  may be indicated by the fact that the fintech company  AO "Kaspi kz" acquired the Ukrainian payment system "Portmone"  in October 2021  ,  which operates in the field of online payments, due to the fact that de facto this Ukrainian company, de jure belonged to the Cypriot law firm  Christodoulos G. Vassiliades & Co LLC. , and through it was connected with the Russian-Ukrainian crime boss  Semyon Mogilevich,  wanted by the US and European Union authorities for his alleged participation in a criminal group and the creation of a scheme as a result of which thousands of investors were defrauded of  more than $ 150 million. The voluminous publication by the American investigative company  Culper Research  also contains other information that compromises the fintech company  AO Kaspi kz  and its beneficiaries. For example, it is stated that in December 2019, the fintech company  AO Kaspi kz  acquired three classifieds sites owned directly by the Kazakh oligarch  Mikhail Lomtadze 




with the aim of expanding operations in Azerbaijan, while these sites themselves could have been transferred to the fintech company at a deliberately inflated price, while today the income in Azerbaijan remains minimal, and the expansion of operations itself, as an argument for the purchase, looks far-fetched.

In addition,  the motives for the acquisition of Alseko JSC by the Kazakh oligarch Vyacheslav Kim also remained unknown  to the authors of the publication "Culper Research"  . As is known,  Alseko JSC  issues invoices, deals with settlements, processes payments of consumers for housing and communal services (HCS)  in Kazakhstan, and the ultimate owner of  Alseko JSC  was considered to be one of the richest businessmen of Kazakhstan  Kairat Boranbayev  and also the company Global Conformity AG registered in Switzerland  ,  while the ultimate beneficiaries of  Global Conformity AG  were never disclosed in the reports, which contradicts  international financial reporting standards (IFRS). And separately, the authors of a voluminous publication by the American investigative company  Culper Research  dwell on the figure of the nephew of the first president of Kazakhstan  Nursultan Nazarbayev  -  Kairat Satybaldy,  who in April 2024 signed a procedural agreement with the Committee for the Return of Assets of the General Prosecutor’s Office of Kazakhstan on a voluntary admission of guilt in the corruption crimes incriminated against him and the return of illegally acquired assets. In particular, the authors of a voluminous publication by the American investigative company  Culper Research  describe in detail the process of laundering  Satybaldy’s funds , obtained by him criminally through accounts in the fintech company  AO Kaspi kz,  both personally and through fictitious and trusted persons, such as the Kazakhstani businessman  Kemal Efendi , and how these funds were subsequently used to purchase real estate in Russia and the UAE. For example, it is described in detail how  Efendi,  as a trusted person  of Satybaldy , with the purpose of laundering money of criminal origin and introducing it into legal circulation, using a power of attorney, deposited and withdrew cash from  Satybaldy’s bank accounts  in the fintech company  AO "Kaspi kz". Thus, only in the period from 2018 to 2022,  Efendi  deposited 53 million tenge  and  150 million dollars in this way into Satybaldy’s bank accounts  , and withdrew  37 billion tenge  from Satybaldy’s accounts.







and  62 million dollars.  Moreover, the voluminous publication lists not only individual transactions, but also indicates that in addition to the actions carried out by  Efendi,   a total of  196 billion tenge  was withdrawn from  Satybaldy’s accounts , which were used to purchase various real estate properties in Kazakhstan and abroad:  22 million dollars  were used to purchase real estate in the UAE, which was purchased from  Satybaldy’s  personal bank account in  AO Kaspi bank  - the funds were transferred to a bank account in the UAE through correspondent accounts in  Bank of New York Mellon  and  AO KB Citibank  between December 2020 and June 2021, similarly, a total of  40 million dollars  were spent from  Satybaldy’s  accounts in  AO Kaspi bank  to purchase luxury real estate in Russia. As a result, the fintech company  AO Kaspi kz  in a voluminous publication by the American investigative company  Culper Research  not only appears as a fintech company that “systematically misled American investors and US regulators,” but is also literally called a symbol of Kazakhstani kleptocracy due to its connections and the connections of its beneficiaries with the political and business elite of the so-called “old Kazakhstan.” It is noteworthy that since the origins of the fintech company  AO Kaspi kz  are  AO Bank Kaspiyskiy,  the American investigative company  Culper Research  points out in its publication those facts that have now been effectively erased from the socio-political space of Kazakhstan, in particular, they cite the story of the former shareholder  of AO Bank Kaspiyskiy Andrey Derkunskiy , who was sentenced in December 2013 to eight years in prison in a case of extortion related to transactions with shares of  AO Kaspi bank  and died in prison under unclear circumstances - according to the official version,  Derkunskiy  committed suicide. In 2005,  Derkunsky  owned  7.2% of the shares  in the original  JSC Bank Kaspiyskiy , but by 2006 he had disappeared from the register of shareholders and years later, in June 2012, he was arrested and found guilty of conspiracy to extort and blackmail one of the beneficiaries of what was then  JSC Kaspi Bank  ,  Vyacheslav Kim , demanding that the latter return  $5.8 million.

Later, during the trial, it was  Derkunsky  who first named the nephew of the first president of Kazakhstan  , Nursultan Nazarbayev  ,  Kairat Satybaldy,  as an undisclosed shareholder  of Kaspi Bank JSC  and stated that  7.2% of the shares  in the original  Bank Caspian JSC  had become the property of  Satybaldy,  and also uncovered an allegedly criminal scheme according to which, at that time,  Kim  purchased shares in the original  Bank Caspian JSC  using funds he received from the same bank in the form of loans issued to companies affiliated with it and relatives.  Derkunsky  was brought to trial

in September 2013 , and fifteen months later he was found hanged while serving a sentence in prison. Official authorities at the time ruled his death a suicide, despite the fact that  Derkunsky’s  cellmate claimed that he was murdered; However, he subsequently retracted his testimony, and the charges related to the circumstances of  Derkunsky’s death  and the case surrounding  Bank Caspian JSC were never investigated further.