The filed complaint alleges that Joint Stock Company Kaspi.kz made materially false and/or misleading statements and/or failed to disclose that: (1) Joint Stock Company Kaspi.kz continued doing business with Russian entities, and also providing services to Russian citizens, after Russia’s 2022 invasion of Ukraine, thereby exposing the Company to the undisclosed risk of sanctions; (2) the Company engaged in undisclosed related party transactions; (3) certain of the Company’s executives have links to reputed criminals; and (4) as a result, defendants’ statements about Joint Stock Company Kaspi.kz’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.