Kazakhstan is tightening export controls in an effort to curb the flow of dual-use goods to Russia, a move prompted by international pressure to prevent circumvention of sanctions imposed on Moscow following its invasion of Ukraine. The measures, introduced on , aim to increase monitoring of goods originating from the European Union, the United States and the United Kingdom, and to restrict their re-export to Russia, particularly through the Commonwealth of Independent States (CIS).
The initiative reflects a growing concern among Western nations that Kazakhstan, and other Central Asian countries, are being used as transit routes for goods that could contribute to Russia’s military capabilities. While Kazakhstan has not formally joined the sanctions regime against Russia – Russia remains Kazakhstan’s largest trade partner, accounting for up to 40% of its non-oil exports – officials in Astana are increasingly sensitive to the risk of secondary sanctions and the potential damage to their economic relationships with the West.
The new regulations mandate export licensing for a range of goods covered by Western sanctions. Ukrainian intelligence reports indicate the controls are designed to reduce re-export flows and strengthen oversight of imported products. A key element of the new regime is a ban on further re-export of these controlled goods within the CIS, with a particular focus on preventing them from reaching Russia. This represents a significant shift in Kazakhstan’s approach, moving beyond simply avoiding direct sanctions violations to actively hindering the flow of potentially sanctioned materials to its northern neighbor.
This tightening of export controls comes after a period of careful neutrality by Kazakhstan regarding the conflict in Ukraine. Since the beginning of the war, Kazakhstani authorities have sought to avoid being caught in the crosshairs of secondary sanctions, even as they maintained economic ties with Russia. One notable example of this was the change in ownership at the two subsidiaries of Russian banks – Alfa Bank and Sberbank – operating within Kazakhstan.
The move also follows increased diplomatic pressure from countries like Germany, which, on , pressed Central Asian nations, including Kazakhstan, to enforce existing sanctions against Russia more rigorously. This pressure underscores the growing international scrutiny of trade routes through the region and the determination of Western governments to close loopholes that allow Russia to access critical technologies and materials.
The implications of Kazakhstan’s strengthened export controls are far-reaching. For Russia, the measures could limit access to dual-use goods – items with both civilian and military applications – that are essential for maintaining its defense-industrial complex. Recent data suggests Russia has already experienced setbacks in key areas, such as oil exports to China, losing its position as the largest supplier to the Chinese market in November, displaced by Saudi Arabia, Oman, and Angola. Further restrictions on access to vital components and technologies could exacerbate these challenges.
However, Kazakhstan faces a delicate balancing act. Maintaining strong economic ties with Russia is crucial for its own economic stability, and any measures that significantly disrupt trade could have negative consequences for the Kazakhstani economy. Astana appears to be attempting to navigate this complex situation by deepening coordination with the European Union on preventing sanction transit while simultaneously seeking to preserve its relationship with Moscow. As one source notes, Kazakhstan is demonstrating a “readiness to narrow Russia’s access to goods critical for the defense-industrial complex” without formally joining the sanctions regime.
The longer-term impact of these controls remains to be seen. The regulations are currently in effect for one year, and This proves unclear whether they will be extended or modified after that period. The effectiveness of the measures will also depend on Kazakhstan’s ability to enforce them rigorously and to prevent the emergence of alternative smuggling routes. The situation highlights the broader challenges of enforcing sanctions in a globalized world and the importance of international cooperation in preventing circumvention.
The issue of re-exportation through Kazakhstan isn’t new. As early as , Kazakhstan announced it would begin monitoring goods imported into the country for re-export, tracking them to their final destination in an effort to prevent sanctions evasion. This latest move represents a significant escalation of those efforts, demonstrating a growing commitment to addressing international concerns about the flow of goods to Russia.
The Eurasian Economic Union (EAEU), of which Kazakhstan and Russia are both members, presents a unique challenge to sanctions enforcement. The EAEU treaty promotes the free movement of goods and services among its member states, and customs duties do not apply within the union. This creates opportunities for goods to enter the EAEU through Kazakhstan and then be re-exported to Russia without facing the same restrictions as direct shipments from Western countries. Kazakhstan’s new export controls are, in part, an attempt to address this loophole.
The situation underscores the increasing pressure on countries in Central Asia to align their policies with Western sanctions against Russia. While these nations are keen to maintain their economic ties with Moscow, they are also aware of the risks of being targeted by secondary sanctions and of damaging their relationships with the United States and the European Union. Kazakhstan’s decision to strengthen export controls is a clear signal that it is taking these concerns seriously.
