The European Union is using Kyrgyzstan as a test case to determine whether anti-circumvention sanctions can succeed in limiting the illicit flow of western technology to Russia, needed by Moscow to maintain its war effort in Ukraine.

In adopting the 20th sanctions package on April 24, the EU banned the export to Kyrgyzstan of computer numerical control machines, which are used in the production of high-precision components for weaponry and telecommunications equipment crucial to drone operations.

The day the sanctions were announced, Kyrgyz President Sadyr Japarov was in Moscow for a Kremlin meeting with Russian President Vladimir Putin.

Though the EU, United Kingdom, United States and Japan have all previously sanctioned individual banks and businesses in Central Asia and the Caucasus, this is the first time “secondary sanctions” have been imposed against an entire country over suspected sanctions-busting behavior.

Whether the anti-circumvention tool will stop Kyrgyz sanctions busters or simply push them to adopt new methods remains to be seen. Kyrgyzstan offers an especially attractive sanctions-evasion route due to its membership in the Russia-led Eurasian Economic Union trading bloc.

The sanctions had loomed for weeks. The mid-April electoral defeat of Hungarian Prime Minister Viktor Orbán’s government, which had been blocking the EU’s new sanctions package against Russia, enabled its adoption.

The EU bans the export of certain “dual-use” goods, which have military and civilian applications, to Russia. However, since 2022, exports of such goods from the EU to Kyrgyzstan have jumped 800 percent, while exports of the same goods from Kyrgyzstan to Russia is 1,200 percent higher, the sanctions decision notes.

In a visit to Bishkek in February, EU sanctions envoy David O’Sullivan urged Bishkek to take firm action to prevent the re-export of dual-use goods to Russia, adding that the EU was not intent on halting all forms of bilateral trade. “We have no intention to interfere with your perfectly legitimate trade and economic relations with Russia, none whatsoever. We respect the closeness of your relations with Russia,” he said, adding that cutting off the transit trade of a few goods would not impact the economy.

In September last year, speaking at the UN General Assembly, President Japarov roundly criticized the sanctions western powers had already levied against Kyrgyz entities. “We consider these baseless sanctions interference in the internal affairs of the country and pressure, which is preventing the development of our still maturing economy,” he said.

Daniyar Amangeldiev, the first deputy cabinet chair, went further in an interview with The Financial Times earlier this year. “This decision [imposing sweeping sanctions] will have consequences for our image. If such a decision is made, we will be ready to challenge it in court,” he said.

During meetings in Washington in mid-April, Kyrgyz Economy Minister Bakyt Sydykov claimed that Bishkek was doing all it could to honor the western sanctions regime. Japarov has repeatedly pointed to Europe and the United States’ continued, though much-reduced, trade with Russia, and he has proposed that an independent audit of the country’s banks be conducted to prove sanctions compliance.

“This isn’t loyalty to Russia, it’s first and foremost loyalty to their own interests,” Putin’s press secretary Dmitry Peskov told reporters after the EU sanctions were announced.

The EU also sanctioned a pair of Kyrgyz banks on April 24, Capital Bank of Central Asia and Keremet Bank, and a cryptocurrency platform Tengricoin, accusing them of providing the Russian defense industry with access to the international finance system in violation of sanctions. The trio of entities were already under sanctions from the United States and United Kingdom over similar allegations. 

Meanwhile, the EU pulled three Tajik banks, Dushanbe City Bank, Spitamen Bank, and Commerce Bank of Tajikistan, which had been included in the 19th sanctions package implemented in November 2025, from the list. 

The three banks hold a fifth of all deposits in Tajikistan, are key to remittance transfers from Russia and are believed to be connected to President Emomali Rahmon’s relatives, Current Time TV, a service of Radio Free Europe/Radio Liberty, reported.

Kyrgyzstan may yet see more sanctions. In an open letter April 23, 20 British MPs and peers called on their government to levy sanctions on the country’s ex-central banker, top financial regulator and the prosecutor-general over sanctions circumvention.

Despite the attention Kyrgyzstan has drawn for sanctions evasion, it is far from the only offender.

Researchers from the Ifo Institute for Economic Research, a think tank in Munich, Germany, wrote in a February 2026 paper that Turkey is the leading pass-through for Russia-bound European military goods. China, Hong Kong and the United Arab Emirates are other common routes, the researchers alleged.

Neither Japarov nor Putin made clear why the former flew to Moscow on April 24 or what was discussed. But in an April 27 interview with the independent outlet Kaktus, Japarov reaffirmed the two countries’ alliance.

“I consider it appropriate to express my thanks to Vladimir Vladimirovich [Putin],” Japarov said. “For the past five years, he has always been supportive on questions of Kyrgyz-Russian cooperation [and] solved problems related to the Russian side. That’s why we call Russia our strategic partner.”