The latest European Union sanctions package against Russia, adopted in late April, also featured sanctions measures against Kyrgyzstan. This was the first use of the EU’s so-called anti-circumvention tools, which are designed to prevent third countries from helping the Kremlin bypass restrictions imposed on Russia over the invasion of Ukraine. If successful, this latest attempt to prevent Russian sanctions evasion could serve as a blueprint for further measures.
The EU’s anti-circumvention tools were first unveiled by the European Commission in June 2023 as a way to “restrict the sale, supply, transfer, or export of specified sanctioned goods and technology to certain third countries.” At the time, this new option was identified as a “last resort measure” when other attempts to prevent third countries from enabling the circumvention of sanctions had already failed.
The move to impose anti-circumvention sanctions, which ban the export of computer numerical control machines to Kyrgyzstan, comes after months of mounting speculation over possible implementation. During a visit to Bishkek in February 2026, EU Sanctions Envoy David O’Sullivan expressed concern over Kyrgyzstan allegedly serving as a transshipment hub for restricted technologies. O’Sullivan claimed European dual-use technologies with both civilian and military applications such as metal-working machines and radio equipment were “being imported into Kyrgyzstan with the sole purpose of being re-exported to Russia.”
The European Commission has echoed these claims. In a statement detailing the recent twentieth Russian sanctions package, EC officials alleged Bishkek was helping Moscow to bypass sanctions in ways that allowed Russia “to pursue its illegal military aggression against Ukraine and sustain its ability to wage war.”
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Kyrgyzstan stands accused of profiting significantly from its position as an economic intermediary providing Russia with sanctioned goods. According to the EU, the export of dual-use technologies from the EU to Kyrgyzstan has increased by nearly 800 percent since the start of Russia’s full-scale invasion in 2022, while exports from Kyrgyzstan to Russia involving sanctioned technologies have grown by 1,200 percent.
The implementation of EU anti-circumvention tools follows other steps against Kyrgyzstan, including measures targeting banks and businesses linked to a billion dollar money laundering scandal that sparked an international probe by investigators from the US, UK, and EU last November. Several British members of parliament are also moving to sanction the head of the Kyrgyz Central Bank along with the country’s financial regulatory authority chief and prosecutor general.
Advocates of the EU’s recently implemented anti-circumvention tools believe they could be particularly effective at cutting off the flow of Western dual-use technologies to Russia. They claim the recent decision sends a clear signal that aiding the Putin regime’s efforts to bypass international sanctions will lead to costs, even for third countries.
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Daniyar Amangaeldiev, Kyrgyzstan’s first deputy cabinet chair, commented earlier this year on the potential damage the EU’s anti-circumvention tools could do to the country’s reputation. Amangaeldiev underlined that steps by Brussels to target Bishkek in this manner would have “consequences for our image.”
Meanwhile, following the recent announcement of the EU’s sanctions measures, Kremlin press secretary Dmitry Peskov stepped forward to defend Bishkek. The Russian official argued that the re-export of dual-use technologies to Russia was a legitimate case of Kyrgyzstan pursuing its own national interests. However, this argument is unlikely to convince those seeking to increase sanctions pressure on Moscow.
The European Union’s anti-circumvention measures against Kyrgyzstan come at a time of widespread frustration over the Kremlin’s apparent ability to bypass existing economic restrictions. This frustration has fueled interest in additional steps that may be able to limit the illicit inflow of sanctioned Western military and dual-use technologies to Russia.
Few would question the need to close existing economic loopholes. Western components are still routinely found in the weapons systems used by Russia in its war against Ukraine. This is possible due to a complex system of international hubs used by the Kremlin to access restricted products. For instance, Moscow currently relies on China for up to 90 percent of its sanctioned technology imports, according to a recent report by Bloomberg.
Ukraine’s allies will be watching closely to gauge whether the EU’s anti-circumvention tools can effectively prevent the flow of restricted goods from Kyrgyzstan to Russia. If this approach proves effective, it could serve as a model for measures against other countries accused of helping Moscow to evade sanctions.
Marc Goedemans is a Young Global Professional at the Atlantic Council’s Eurasia Center.
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Image: Russian President Vladimir Putin and Kyrgyz President Sadyr Japarov shake hands as they pose for photos before a meeting at the Yntymak Ordo Presidential Administration in Bishkek, Kyrgyzstan. November 26, 2025. (Sputnik/Alexander Kazakov/Pool via REUTERS)