The European Union expresses concern about the circumvention of imposed sanctions. Previously, a number of financial institutions from Kyrgyzstan were included in the 19th sanctions package against Russia, and the 20th package, which is currently under negotiation, may also affect organizations from Kyrgyzstan.
O'Sullivan emphasized that the EU does not require Kyrgyzstan to join the sanctions: "We understand that some countries, for various reasons, decide not to do so," he noted.
The Special Representative indicated that the European Union is not asking Kyrgyzstan to "stop trading with Russia." Instead, he stated that the EU is obliged to protect its interests, and the sanctions are directed not against the state but against specific organizations.
"We urge Kyrgyzstan not to allow its territory to be used by unscrupulous entities to circumvent sanctions, especially concerning the transit of European goods whose export to Russia is prohibited," O'Sullivan concluded.
According to Bloomberg, in January 2026, the European Union is considering the introduction of restrictive measures against Kyrgyzstan related to assistance from Russia in circumventing sanctions.
As part of the new sanctions package against Russia, the European Union plans to use for the first time a tool to counteract the circumvention of sanctions, which may prohibit the export of machinery and certain radio equipment to Kyrgyzstan.
The First Deputy Prime Minister of Kyrgyzstan, Daniyar Amangeldiev, commented on the situation regarding possible new sanctions at the Munich Security Conference.
He noted that the Cabinet of Ministers of Kyrgyzstan regularly interacts with David O'Sullivan on these issues.
Amangeldiev added that Kyrgyzstan's selection as a target of the EU's sanctioning attention appears intimidating and resembles the approach of "hit the small ones so that the big ones are afraid," which the Kyrgyz side 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, including a major bank and oil and gas companies. Secondary sanctions apply not only to financial institutions and oil but also to companies engaged in:
- the supply of electronic and telecommunications equipment,
- IT infrastructure,
- aviation fuel,
- air transport, and more.
Economist from the Brookings Institution Robin Brooks reported a significant 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%, as well as from Norway, the United Kingdom, Germany, and the Czech Republic — by more than 1,000%.
