The European Union expresses concern about the potential circumvention of sanctions through the transit of dual-use goods that may be used in the military sphere.
O'Sullivan noted that the EU is observing a significant increase in the import of certain goods from Europe to Kyrgyzstan, as well as comparable volumes of their export to Russia.
“Our concerns are primarily related to machinery and radio equipment. We have reason to believe that these goods are being imported solely for the purpose of subsequent re-export to Russia, which violates our sanctions,” he stated.
“These goods are not produced in Kyrgyzstan and are not used here. We are confident that their import is carried out solely with the intent to circumvent sanctions. These are the issues we are discussing with the Kyrgyz authorities,” O'Sullivan added.
He explained that although the absolute figures of the commodity flow are small, in percentage terms compared to data from before 2022, this represents “a significant increase of hundreds of percent.”
“These goods are inexpensive, and for a small amount of money, one can obtain many items that can be used in drones and missiles,” he noted.
According to the representative, the EU has identified 80 product categories whose re-export raises particular concern among European countries.
As reported in January 2026, Bloomberg informed that the European Union is preparing a series of measures against Kyrgyzstan due to its assistance to Russia in circumventing sanctions.
As part of a new sanctions package against Russia, the European Union is considering applying its tool to combat sanctions circumvention, which could prohibit the export of machinery and radio equipment to Kyrgyzstan.
The First Deputy Prime Minister of Kyrgyzstan, Daniyar Amangeldiev, commented on the possibility of new sanctions at the Munich Security Conference.
He noted that Kyrgyzstan regularly interacts with David O'Sullivan, the EU Special Representative for Sanctions, on this issue.
Amangeldiev emphasized that the choice of Kyrgyzstan as a target for EU sanctions measures appears intimidating and resembles the principle of “beat the small so the big are afraid,” with which the Kyrgyz side disagrees.
Note:
Since the beginning of 2022, more than 20 companies from Kyrgyzstan have been subjected to sanctions by the U.S. and U.K. Treasury, including major banks and oil and gas companies. Secondary sanctions affect not only the financial sector and the oil industry but also companies involved in supplies:
- telecommunications and electronic equipment,
- IT infrastructure,
- aviation fuel,
- air transport, and others.
Economist Robin Brooks from the Brookings Institution 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%, as well as from Norway, the U.K., Germany, and the Czech Republic — by more than 1,000%.
