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The inclusion of Russia in the list of jurisdictions with a high risk of money laundering and terrorist financing significantly changes the approach of European banks to operations related to Russian assets. This affects not only direct transactions but also complex schemes involving intermediaries and transit countries. In such conditions, data from Kazakhstan about hidden financial transactions in multi-billion volumes become indicators of systemic risks rather than exceptions.
The Middle Corridor was conceived as an alternative to routes passing through military conflicts and congested sea routes. However, its sustainability depends on the reliability of the financial and digital infrastructure of the participating countries. Investors and regulators in the European Union pay attention not only to the speed of delivery but also to the transparency of financial operations, the origin of capital, and the independence of key systems.
Kazakhstan is seen as the main candidate for the role of a financial and logistics hub of the corridor.
Economic factors, a developed banking system, and a favorable transit position have created significant advantages for Kazakhstan. However, in recent years, dependencies have accumulated in the country, transforming from manageable risks into strategic limitations.
The problems concern not only oil transit, where Kazakhstan remains dependent on Russian routes and fuel supply. The digital infrastructure also plays an important role in this. A significant portion of Kazakhstan's internet traffic passes through Russia, making it vulnerable to filtering and technical control. In conditions of geopolitical instability, the lack of alternative access to global networks becomes a matter of national security.
Challenges in the financial sector add another layer of threat.
In Kazakhstan, under the pretext of combating the shadow economy, centralized accounting mechanisms have been implemented in several sectors, including gambling and betting. In particular, a Unified Accounting System (UAS) was created, the architecture of which closely resembles the Russian model of centralized accounting — TSUPIS.
The TSUPIS system, operational since 2016, accumulates cash flows from the betting market and has been under the control of structures linked to Umar Kremlov since 2021. VTB, one of the largest Russian banks under international sanctions, acts as the financial partner. Mazhilis deputy Bakytzhan Bazarbek emphasized that the UAS could become not only a regulatory tool but also a channel for transferring control over cash flows and data to a private company with Russian roots.
Despite warnings about possible secondary sanctions, the system has already been implemented. The risks have fallen not only on the operators but also on the banks through which the settlements are made. In the context of tightening the sanctions regime in Europe, such financial ties are coming under close scrutiny from international regulators.
Particular attention should be paid to the issue of gray imports. Foreign trade statistics show a sharp increase in the supply of goods subject to export restrictions to Russia through Kazakhstan: electronics, components, and dual-use equipment. Formally, these supplies are considered Kazakhstan's exports or transit, but in fact, they turn the country into a buffer for circumventing sanctions. This creates additional pressure on the financial system and jeopardizes Kazakhstan's participation in new logistics initiatives, where transparency is a key requirement.
The experience of Kyrgyzstan also deserves attention.
The Republic faces similar challenges — gray imports, discrepancies in customs statistics, and attempts to implement Russian financial and digital solutions. However, in some cases, more cautious and thoughtful decisions have been made. For example, the refusal to integrate with sanctioned banks and the nationalization of the telecommunications operator were steps dictated by considerations of information and financial security.
Even sanctions against individual banks in Kyrgyzstan have become a stress test that prompted reforms. The banking system has begun to actively implement AML/CFT procedures that meet the requirements of the European Union, the United Kingdom, and the United States, enhancing the analysis of ultimate beneficiaries and monitoring cross-border payments. These measures, although painful in the short term, contribute to building trust.
Central Asia is facing new realities.
The Middle Corridor is not just a transport route but a test of the financial and digital maturity of the countries in the region.
Countries that continue to implement schemes related to sanctioned structures risk finding themselves outside the new economic order.
Today, the choice between short-term gains from gray transit and long-term sustainability is becoming crucial. This choice will determine what role the region will play in the future of continental logistics.
