To mark the second anniversary of Russia’s full-scale invasion of Ukraine last week and the recent death of Russia opposition politician Alexei Navalny, the U.S. Department of the Treasury’s Office of Foreign Assets Control announced sanctions on almost 300 individuals and entities.
Embedded in the list were a handful of Central Asian companies. The latest round of sanctions designations included the Bishkek-based Obshchestvo S Ogranichennoy Otvetstvennostyu Ukon (Ukon). As Kloop reported, citing a Ministry of Justice database, Ukon was founded in August 2022, six months after the launch of the Russian invasion of Ukraine, by Gafar-Zadeh Mehdi Fikret Oglu. Registration details note the company’s main activity as “wholesale non-specialized trade.”
According to the U.S. Treasury Department’s sanctions, Ukon “has sent aircraft components and U.S.-origin aircraft parts in violation of U.S. export control regulations to Russia-based end-users.”
The United Arab Emirates (UAE) company PolarStar Logistics, which has branches in the UAE, Uzbekistan, and India, was also added to the sanctions list. The company, the U.S. Department of State said, “offers cargo shipping services from the UAE to Russia” and is listed as a S7 Airlines (Siberia Airlines) representative office. S7 Airlines was added to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) “Entity List” in June 2022 in an expansion of aviation-related export controls and sanctions.
Two Kazakh companies, Astana-based Da Group 22 and Almaty-based Elem Group were also included in the list. Registration details for both companies list them as being engaged in the trade of electronic and telecommunication equipment and parts. Da Group also, per registration information, produces circuit boards and Elem was additionally engaged in “forwarding services.”
The U.S. Department of State said that Da Group 22 was “receiving common high-priority items” from a Germany-based company, and was “sending common high-priority items” to a Russia-based company. “The end users of these common high-priority items include the Russian military and Russian space and defense manufacturers,” State noted.
Meanwhile, Elem Group “has supplied common high-priority items to Russia-based, U.S.-designated [Streloi Ekommerts],” itself a wholesaler of electronic equipment and parts.
According to the National Information and Analytical Center which provides a public registry of Kazakh companies both Da Group 22 and Elem Group were registered on March 14, 2022 – mere weeks after the Russian invasion began.
The Kazakh Ministry of Trade and Integration told TASS that it had been informed in advance that the companies would be listed as part of a “constructive dialogue.” The ministry also stated that as of May and June of 2023, respectively, the two companies had not carried out any import or export activities. The ministry also noted that Elem Group was in the process of liquidation.
While the number of Central Asian individuals and companies subject to sanctions stemming from the Russian war remains small, each additional designation underscores the region’s precarious position. Not only are Central Asia economies invariably impacted by sanctions targeting Russia, given the deep economic connections within the former Soviet space, but the war presented a unique opportunity for certain entrepreneurs interested in skirting sanctions, or at the very least in flirting with the possibility. It is notable that the newly sanctioned Central Asian companies (with the exception of the Uzbekistan-based office of PolarStar Logistics) were all registered after the start of the war.
Here we encounter the murky world of parallel imports and re-exports. Notably increased export and import figures in countries like Kyrgyzstan and Kazakhstan over the past two years are arguably the result of goods being imported into the Central Asia countries and then re-exported to Russia. These trade patterns have made Central Asia countries vulnerable to secondary sanctions. That said, the U.S. and EU, which are leading the sanctions regime against Russia, have been diligent in reaching out to Central Asian countries. This is reflected in Kazakh Ministry of Trade and Integration’s comments to TASS.
While Kazakhstan, like the rest of Central Asia, has not joined international sanctions against Russia, Astana has been adamant in stating, repeatedly, that it will not allow Kazakh territory to be used to circumvent sanctions. This sentiment has been echoed across the region.
Last year, in the wake of RFE/RL reporting on Kazakh and Kyrgyz companies exporting sanctioned dual-use goods to Russia and subsequent reporting by the Washington Post that the Biden administration was preparing sanctions on Kyrgyz companies, several Kyrgyz companies were sanctioned. Kyrgyz authorities responded quickly with the State Committee for National Security putting out a statement in which it said it “admits the possible involvement of private companies and firms… which, as part of their business and production activities, could be involved in violations of sanctions restrictions, possibly without knowing who actually can be the end consumer and user of the products supplied to them.” The statement added that the Kyrgyz state itself was not involved in violating sanctions.
Two years on, the war in Ukraine is slogging on and it’s clear that the U.S. and EU are watching closely and pulling on the loose threads – even those that tie back to Bishkek.