Last year, on the second anniversary of the Russian invasion, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury published yet another list of sanctioned companies and individuals. The list contained only a handful of Central Asian entities.[1] This handful was a sign that the Western threats of secondary sanctions were finally beginning to materialise.
As we enter the fourth year of the invasion, Central Asian governments are still managing to keep an exterior of relative neutrality while playing a dangerous balancing game between Russia, China and the West. The threat of secondary sanctions by the US, UK, and the EU has been there from the very outset, but over the last year they have finally hit home, albeit to a relatively modest extent.[2]
After the full scale invasion, Central Asia provided relatively easy routes for dual-use commodities to reach Russia from China and Europe alike thanks to the region’s comparatively open borders, favourable trade laws, and opportunistic intermediaries on the ground.[3] The signs of booming trade with Russia and a sudden increase in EU exports to Armenia, Kazakhstan and Kyrgyz Republic (member-states of the Eurasian Economic Union, a Russia-led regional economic integration project) speaks volumes.[4],[5]
Those are not necessarily state-sanctioned activities, but most likely initiatives of profit-driven locals, as well as external exploitation of Central Asian economic regimes, which were designed to attract foreign investment and so-called “digital nomads” – foreign freelancers, who are able to work remotely and spend their money in Central Asian countries. In one of the notorious cases of sanctions evasion, British military technologies were traded through a company set up in Central Asia by a Belarussian Instagram model.[6]
The Central Asian governments have to deal with the repercussions though. Secondary sanctions affect credibility of the Kyrgyz banking and financial sector, significantly limit Kyrgyz citizens’ ability to use global payment systems, such as Visa and Mastercard, and set a shadow on foreign investment prospects. In addition to these, there are political repercussions too. Russian Prime Minister Mishustin has already attempted to pressurise the Kyrgyz Government for ‘unfairly targeting’ Russian businesses in Kyrgyzstan. The response to this accusation was strong and decisive: no one can be given an unreasonable advantage.[7]
To what extent the sanctions would and could work remains dubious. Lists of sanctioned entities take time and effort to emerge, while intermediary companies spring up like mushrooms in the region. It finally hits home, but not hard enough to induce any meaningful change.
Dr. Aijan Sharshenova is a Foreign Policy Centre Research Fellow.
Disclaimer: The views expressed in this piece are those of the author and do not reflect the views of The Foreign Policy Centre.
[1] Catherine Putz, ‘US puts additional Central Asian companies on Russia sanctions list’, The Diplomat, 28 February 2024, https://thediplomat.com/2024/02/us-puts-additional-central-asian-companies-on-russia-sanctions-list/
[2] Claire Mills, ‘Sanctions against countries supporting Russia’s invasion of Ukraine’, research briefing, House of Commons Library, 17 January 2025,https://commonslibrary.parliament.uk/research-briefings/cbp-10048/
[3] Samantha Fanger, ‘Central Asia’s Gateway of Dual-Use Technology and Materials to Russia’. Caspian Policy Center, 28 March 2024, https://www.caspianpolicy.org/research/security/central-asias-gateway-of-dual-use-technology-and-materials-to-russia?mc_cid=7751d6b298&mc_eid=221261e860
[4] Aijan Sharshenova, ‘The Eurasian Economic Union: Pros and cons for smaller member-states’, ISPI Online Dossier, 03 February 2025, https://www.ispionline.it/en/publication/the-eurasian-economic-union-pros-and-cons-for-smaller-member-states-199114
[5] Maxim Chupilkin, BeataJavorcik, and Alexander Plekhanov, ‘The Eurasian roundabout: Trade flows into Russia through the Caucasus and Central Asia’, EBRD Working Paper no.276, https://www.ebrd.com/publications/working-papers/the-eurasian-roundabout
[6] Angus Crawford and Tony Smith, ‘UK war tech sent to Russia by Insta model’s firm, documents seen by BBC show’, BBC News Investigations, 20 November 2024, https://www.bbc.com/news/articles/cn4vzlx1350o
[7] Eurasianet, ‘Kyrgyzstan resists Russian pressure to give sanctions-busting firms lenient treatment’, Eurasianet News, 04 February 2025, https://eurasianet.org/kyrgyzstan-resists-russian-pressure-to-give-sanctions-busting-firms-lenient-treatment