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.”
