Under a proposed 20th package of sanctions against Russia, which are expected to be introduced by the end of February, Kyrgyzstan could starting facing certain export restrictions.
The EU is currently weighing a proposal that would target export bans for at least two dual-use items, CNC machines and radio equipment, diplomatic sources have confirmed to RFE/RL.
The measure is being considered amid concerns in Brussels that certain dual-use goods exported to Kyrgyzstan may be re-exported to Russia, helping to circumvent existing sanctions.
Dual-Use Imports
CNC machines -- computer-controlled tools that cut, drill, and shape materials -- are widely used in industries from car manufacturing to electronics. But they can also be used to make parts for missiles, aircraft, and other military systems. Similarly, radio equipment is used for everyday communications but can also serve military purposes from battlefield communications to drone control.
Both are classified as dual-use items, meaning they have civilian and military applications and are tightly controlled by EU export rules.
While exact Kyrgyz imports are hard to track, EU trade data shows that Germany, Italy, France, and Poland supply the country with industrial machinery and electronic equipment that include CNC and radio components. Russia has historically relied on these European-made tools for advanced military production, which explains why such exports are tightly monitored and could trigger sanctions if diverted.
RFE/RL sources emphasize that the sanctions package is still at the drafting stage. Any EU sanctions package requires unanimous approval from all 27 member states, and negotiations can lead to changes, delays, or the removal of individual provisions. EU diplomats told RFE that some manufacturing countries may oppose the sanctions to protect their business interests and trade partnerships with Kyrgyzstan.
The proposed 20th package is being prepared ahead of the fourth anniversary of Russia's full-scale invasion of Ukraine, with a decision expected by the end of February.
Bloomberg, which first reported on the draft package, said it would expand existing measures against Russian banks and energy companies and could also target cryptocurrency services and financial institutions in third countries suspected of helping Russia bypass restrictions.
First In Line For EU Specific Sanctions
If restrictions on exports to Kyrgyzstan are approved, they would constitute the first application of the EU's anti-circumvention instrument, introduced in 2023. This tool allows the EU to limit exports of specific sensitive goods to an entire third country if there is evidence those goods are systematically re-exported to Russia.
Unlike traditional sanctions, it does not require proof that a government intentionally violated sanctions and doesn't represent a full trade embargo. Instead, it focuses on narrow, sector-specific export bans.
The draft package reflects growing concern in Brussels about transit routes for sanctioned goods through Central Asia. As a reflection of such concerns, Kyrgyzstan would become the first post-Soviet country within Russia's sphere of influence to be targeted with EU sanctions at the state level, marking a significant escalation beyond sanctions on individual companies.
For Kyrgyzstan, the use of this mechanism would go beyond reputational damage. Economically, export bans on European machinery and electronics could disrupt supply chains, increase costs for businesses reliant on EU technology, discourage foreign investment, and make European banks and insurers more cautious in dealing with Kyrgyz counterparties. Once imposed, such measures are difficult to reverse and require sustained proof that re-exports have stopped.
Big Blow For A Small Country
Marat Musuraliev, deputy director of Smart Business Solutions Central Asia, warned that if the EU eventually applies country-level export restrictions, it would significantly harm Kyrgyzstan's reputation and economic prospects.
"If individuals and private companies have profited from bypassing sanctions, and the EU sanctions the country, then we will all bear the consequences. It's easy to fall under sanctions, but very difficult to get out. This will cause serious damage to our economy," he said. "It's also a reputational issue. Anyone considering investing in Kyrgyzstan will not just think once. They will think seven times before making a decision."
Certain trade patterns and business activities have raised red flags for EU officials and independent observers since Russia's full-scale invasion of Ukraine. Studies from 2023–2024 by the US-based Brookings Institution documented a sharp rise in exports from Europe and other regions to Central Asia and the Caucasus, with many of those goods later appearing in Russia.
Brookings economist Robin Brooks said Kyrgyzstan became a key destination for European exports, citing dramatic increases from several EU countries.
He reported that since February 2022, exports to Kyrgyzstan rose by 10,000 percent from Estonia, 3,100 percent from Finland, 2,200 percent from Poland, and 2,100 percent from Greece -- noting that not all exporters were involved in circumventing sanctions.
Investigations by RFE/RL's Kyrgyz Service, known locally as Radio Azattyk, from 2023 also documented how certain Western dual‑use goods not previously imported into Kyrgyzstan were being exported in ways that helped them reach Russia despite sanctions.
Western governments, including the EU, the United States, and the United Kingdom, have already imposed secondary sanctions on individual companies and banks in third countries that expanded trade with Russia.
In Kyrgyzstan, around 25 private entities, including banks and trading firms, have been placed on Western sanctions lists. However, Kyrgyzstan as a state has never been sanctioned. Any EU decision to restrict exports to the country would therefore represent a significant shift in approach, even if limited in scope.
Playing Clean
Kyrgyz authorities have strongly denied claims the country is facilitating sanctions evasion. First Deputy Chairman of the Cabinet of Ministers Daniyar Amangeldiev told Radio Azattyk that Bishkek has received no official notification regarding sanctions against Kyrgyzstan and that information about possible measures has so far come only from media reports.
"We are holding consultations with EU Special Envoy for Sanctions David O'Sullivan and have imposed restrictions on the export of weapons and sensitive goods. Trade statistics based on percentage growth can also be misleading when initial volumes were very low," he said.
Sanctions imposed on Kyrgyz banks have been a particular concern for the government. Of the country's 23 banks, four -- Tolubay Bank, Eurasia Savings Bank, Keremet Bank, and Capital Bank -- were sanctioned over alleged involvement in suspicious financial schemes.
In September last year, President Sadyr Japarov addressed the issue at the UN General Assembly, calling for the removal of sanctions on Kyrgyz banks and offering international audits. He emphasized that Kyrgyzstan pursues a multivector foreign policy, maintains economic ties with Russia, and does not support the war in Ukraine.
At the same time, Western regulators have raised concerns over the activity of Russia-linked cryptocurrency businesses in Kyrgyzstan.
In 2025, the Grinex crypto exchange -- launched in Kyrgyzstan by Moldovan oligarch Ilan Shor -- and the ruble-pegged A7A5 stablecoin became subjects of international scrutiny. The US Treasury's Office of Foreign Assets Control, the UK government, and the EU imposed sanctions on Grinex, the company behind the A7A5 stablecoin, and their founders.
Radio Azattyk estimates that transactions involving A7A5 totaled $79 billion, while other media reports said that by early 2026 funds circulating through Grinex exceeded $100 billion.
