The European Union expresses concern about the circumvention of sanctions, particularly regarding the transit of dual-use goods that may be used in the military industry.
O'Sullivan noted that "these goods constitute only a small share of the overall trade between the EU and Kyrgyzstan and, for the most part, do not represent an economic interest for the country." According to him, such products, as claimed by the EU, are not processed in Kyrgyzstan: they come from Europe and are instantly exported to Russia, bringing no significant benefit to the republic's economy.
The Special Representative reported that the EU has identified 80 product items, the re-export of which raises serious concerns among European countries.
First category: 50 HS codes
— These goods have been observed in armaments on Ukrainian battlefields.
Second category: 30 HS codes
— These are raw materials necessary for Russia's military industry, which are sent to Russian factories.
According to Bloomberg, new restrictive measures from the EU against Kyrgyzstan are expected in January 2026 due to its assistance to Russia in circumventing sanctions.
As part of a new sanctions package against Moscow, the European Union is considering the possibility of applying, for the first time, a tool aimed at countering the circumvention of sanctions, which could prohibit the export of machinery and certain radio equipment to Kyrgyzstan.
The First Deputy Chairman of the Cabinet of Ministers of the Kyrgyz Republic, Daniyar Amangeldiev, commented on the potential new sanctions at the Munich Security Conference.
He emphasized that the Kyrgyz government regularly interacts with the EU Special Representative for Sanctions, David O'Sullivan, on this issue.
Amangeldiev noted that the attention given to the Kyrgyz Republic by European sanctioning bodies has a frightening character and reflects the principle of "hit the small so the big ones fear," which the Kyrgyz side categorically disagrees with.
Note:
Since the beginning of 2022, more than 20 companies from Kyrgyzstan have been sanctioned by the U.S. and U.K. Treasury. Among them are a major bank and oil and gas enterprises. The secondary sanctions against the country concern not only financial institutions and the oil sector but also companies engaged in supplies:
- electronic and telecommunications equipment,
- IT infrastructure,
- aviation fuel,
- air transport, and others.
