This Regulation introduced an indefinite freeze on the assets of the Bank of Russia, which, according to the Central Bank of the Russian Federation, deprived it of the ability to seek judicial protection for its violated rights to these assets. The regulator also emphasizes that this decision violates access to justice, the inviolability of property, as well as the principle of sovereign immunity for states and their central banks.
Furthermore, the Central Bank of the Russian Federation pointed out serious procedural violations in the adoption of the contested Regulation, as it was approved by a majority vote rather than unanimously, which contradicts the requirements of Article 215 of the Treaty on the Functioning of the European Union.
At the beginning of 2026, it became known that the European Union is developing restrictive measures against Kyrgyzstan due to its assistance to Russia in circumventing sanctions.
The European Union is considering the possibility of applying its tool to counteract sanctions circumvention within the framework of the 20th package, which may prohibit the export of certain radio equipment and machinery to Kyrgyzstan.
The First Deputy Prime Minister Amangeldiev noted in an interview with the Financial Times that such sanctions could seriously harm Kyrgyzstan's reputation and slow down its development.
“If such a decision is made, we will be ready to challenge it in court, as it will negatively affect our image,” FT quotes the Deputy Prime Minister.
Later, the Cabinet clarified that the discussion concerned a hypothetical scenario of possible sanctions, and Kyrgyzstan does not intend to sue the EU in the context of sanctions against Russia.
The EU Special Representative for Sanctions, David O’Sullivan, while in Bishkek on February 26, reported that specific steps had been proposed to the Kyrgyz side for further technical cooperation aimed at removing Kyrgyz banks from the sanctions list and preventing financial risks in the future.
The Kyrgyz side, in response, emphasized that the control over the supply of sanctioned goods should also be carried out by European exporters.
Deputy Chairman of the National Bank of the Kyrgyz Republic Azat Kozubekov reported on February 24 that government agencies are taking measures to minimize the possible negative consequences of the expected 20th package of sanctions against Russia and their impact on the banking sector of Kyrgyzstan.
“Work in this direction is being carried out systematically and methodically by both the Cabinet of Ministers and the National Bank. We are trying to minimize the negative impact of such sanctions packages on the Kyrgyz Republic,” Kozubekov noted.
