The European Union expresses concern about the circumvention of sanctions, especially in the context of the transit of dual-use goods that may be used in the military sphere.
O'Sullivan noted that in recent years there has been a significant increase in the volumes of certain goods that Kyrgyzstan purchases in Europe and sends to Russia.
“This primarily concerns machinery and radio equipment. We have reason to believe that these goods are imported with the intention of re-exporting them to Russia, which constitutes a violation of our sanctions.
These goods are not produced in Kyrgyzstan and are not used in the country. We are confident that their import is carried out solely for the purpose of circumventing sanctions. We are actively discussing these concerns with the Kyrgyz authorities,” he stated.
He added that although the absolute figures for the commodity flows are small, there has been a “huge increase of hundreds of percent” in percentage terms compared to 2022.
“These goods are small and relatively inexpensive. For a moderate amount of money, one can acquire a significant quantity of equipment that can be used in drones and missiles,” O'Sullivan clarified.
The Special Representative also mentioned that the EU has identified 80 commodity items whose re-export raises concerns among European countries.
According to Bloomberg, in January 2026, it became known that the EU was preparing restrictive measures against Kyrgyzstan related to its support for Russia in circumventing sanctions.
As part of a new sanctions package against Moscow, the European Union is considering the possibility of applying a tool to counteract sanctions evasion for the first time, which would 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 introduction of new sanctions at the Munich Security Conference.
He emphasized that the Cabinet of Ministers of the Kyrgyz Republic regularly interacts with David O'Sullivan on this issue.
Amangeldiev noted that the choice of the Kyrgyz Republic as a focus of attention for European sanctions structures raises concerns and reminds one of the principle "hit the small so the big are afraid," which the Kyrgyz side does not agree with.
Note:
Since the beginning of 2022, more than 20 companies from Kyrgyzstan have been included in the sanctions lists of the U.S. and U.K. Treasury. Among them are major banks and oil and gas companies. Secondary sanctions against the country concern not only the financial sector and oil but also companies involved in supplies:
- telecommunications and electronic equipment,
- IT infrastructure,
- aviation fuel,
- air transport, and other areas.
Brookings Institution economist Robin Brooks reported a sharp increase in export supplies from Europe to Kyrgyzstan: from Estonia — by 10,000%, from Finland — by 3,100%, from Poland and Greece — by 2,200% and 2,100%, while Norway, the United Kingdom, Germany, and the Czech Republic also showed growth of more than 1,000%.
