According to this Regulation, EU authorities established an indefinite freeze on the assets of the Bank of Russia.
The Central Bank of Russia claims that the European Union excluded the possibility of judicial protection for violated rights to assets. The regulator also states that there has been a violation of rights to access to justice, property protection, and the principle of sovereign immunity for states and their central banks.
Furthermore, the Central Bank noted that serious procedural violations occurred during the adoption of the contested Regulation: it was adopted by a majority vote, bypassing the requirements of Article 215 of the Treaty on the Functioning of the European Union, rather than by unanimous decision of EU members.
In January 2026, it became known that the European Union was preparing a series of restrictive measures against Kyrgyzstan, triggered by Russia's assistance in circumventing sanctions.
As part of the 20th package of sanctions against Moscow, the EU is exploring the possibility of applying a tool to counteract sanctions evasion, which would prohibit the export of machinery and certain radio equipment to Kyrgyzstan.
First Deputy Prime Minister Amangeldiev stated in an interview with the Financial Times that such sanctions could significantly damage Kyrgyzstan's reputation and slow down its development.
“The adoption of such a decision will reflect on our image. If it is approved, we will be ready to challenge it in court,” FT quotes the Deputy Prime Minister.
Later, the Cabinet clarified that they discussed a hypothetical scenario of possible sanctions. Kyrgyzstan does not intend and does not plan to file a lawsuit against the EU regarding sanctions against Russia.
David O'Sullivan, the EU Special Representative for Sanctions, during a visit to Bishkek on February 26, reported that specific proposals for technical cooperation had been sent to the Kyrgyz side to remove Kyrgyz banks from the sanctions list and minimize financial risks in the future.
For its part, Kyrgyzstan stated that control over the supply of sanctioned goods should also be carried out by European exporters.
Deputy Chairman of the National Bank of Kyrgyzstan Azat Kozubekov reported on February 24 that government agencies are taking measures to minimize possible negative consequences from the expected 20th package of sanctions against Russia and their impact on the banking sector of Kyrgyzstan.
“In general, the work carried out by the Cabinet of Ministers and the National Bank is being conducted systematically and consistently. We are taking all possible measures to reduce the negative impact of such sanction packages on the Kyrgyz Republic,” Kozubekov noted.
