The European Union expresses concern about the circumvention of sanctions, particularly concerning dual-use goods that may be used in the military industry.
“These goods constitute only a small part of the overall trade between the EU and Kyrgyzstan and, primarily, do not have economic significance for the republic,” O'Sullivan noted.
According to EU representatives, such products are not used in Kyrgyzstan's manufacturing processes: they come from European countries and are immediately re-exported to Russia, bringing no tangible benefit to Kyrgyzstan's economy.
The EU Special Representative reported that a total of 80 product positions raise concerns among European states in the context of re-export.
First group: 50 HS Codes
— Goods that have been documented as being used on the battlefield in Ukraine.
Second group: 30 HS Codes
— Raw materials critically important for the Russian military industry and sent to Russian factories.
According to Bloomberg information published in January 2026, the European Union plans to introduce a series of restrictive measures against Kyrgyzstan in connection with its assistance to Russia in circumventing sanctions.
As part of the new sanctions package against Moscow, the European Union is considering the possibility of applying tools to prevent the circumvention of sanctions, which could lead to a ban on the export of machinery and certain radio equipment to Kyrgyzstan.
First Deputy Prime Minister of the Kyrgyz Republic Daniyar Amangeldiev commented on the possible 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, the EU Special Representative for Sanctions, on this issue.
Amangeldiev noted that the attention to the Kyrgyz Republic from European sanctioning bodies has a frightening nature and resembles the principle of "beat the small so that the big are afraid," which the Kyrgyz side disagrees with.
Note:
Since the beginning of 2022, more than 20 companies from Kyrgyzstan have been subjected to sanctions by the U.S. and U.K. Departments of the Treasury, including a major bank and oil and gas companies. Secondary sanctions affect not only financial institutions and the oil sector but also impact companies engaged in:
- the supply of electronic and telecommunications equipment,
- IT infrastructure,
- aviation fuel,
- air transport, and others.
