Russia is using the states of Central Asia, above all Kazakhstan, as a key channel for circumventing Western sanctions imposed after February 2022. This includes the parallel import of dual-use goods, re-exports and financial operations. Despite the blocking of leading Russian banks from the SWIFT system and similar mechanisms, these institutions continue to participate in the lending and financing of projects in Kazakhstan through local subsidiaries and intermediaries (The Diplomat, “Emerging Russian Firm Takes Place of Sanctioned Lender in Central Asia”, 21 December 2024)
According to Western analysts, the volume of re-exports of critically important goods (microelectronics, CNC machine tools, optics) from Kazakhstan to Russia in 2023–2025 increased by 35–48 per cent compared with pre-sanctions levels, as confirmed by EAEU customs statistics and US intelligence reports. Kazakhstan remains the most convenient route due to the absence of internal customs controls within the EAEU, its well-developed logistics infrastructure and the possibility of using third currencies—primarily the Chinese yuan—for settlements (Lansing Institute, “Kazakhstan as Russia’s Sanctions Evasion Hub: 2025 Update”, December 2025). In addition, a significant role is played by cryptocurrency schemes and nominal companies registered in Kazakhstan’s free economic zones, which make it possible to obscure the final recipient of goods.
In 2025–2026, within the framework of the 19th sanctions package, the EU introduced transaction bans against certain Kazakh banks (including VTB Bank Kazakhstan), as well as banks in Kyrgyzstan and Tajikistan, for facilitating sanctions evasion. Similar measures are being discussed in the context of the 20th package (Council of the European Union, press release “19th package of sanctions against Russia”, 23 October 2025: The Diplomat, “More Central Asian Banks Sanctioned by the EU”, 24 October 2025).
The Kazakh authorities officially deny systematic assistance to Russia and have strengthened export controls, which led to border delays and a reduction in the re-export of sanctioned goods by 18–22 per cent in the first quarter of 2026. Nevertheless, the risks of secondary sanctions remain. In January 2026, President Tokayev publicly stated that “Kazakhstan will not become a bypass route for violating international law” (Kazinform, “Tokayev: Kazakhstan will not be used to circumvent sanctions”, 15 January 2026). In practice, however, the continued high level of trade with Russia (more than 20 per cent of Kazakhstan’s foreign trade turnover) creates objective difficulties for a complete severance of such chains.
International commodity traders Glencore and Trafigura maintain a significant presence in the region. Glencore is negotiating the sale of its 70 per cent stake in Kazzinc to a local businessman, Shakhmurat Mutalip (estimated value of the deal: USD 4–4.5 billion); the company may also provide financing (Bloomberg, “Kazakh Building Tycoons Pivot to Mining as Power Shifts”, 27 November 2025; Mining.com, “Glencore said to close in on sale of Kazzinc mining operations”, 19 February 2026).
Trafigura continues to operate with Kazakh mining assets and, through joint ventures with local companies, supplied equipment and financed projects worth more than USD 800 million in 2025. Formally, these transactions do not fall under direct sanctions against Russia; however, their profitability and indirect links to Russian interests allow economic flows favourable to sanctioned structures to be maintained (Reuters, “Trafigura expands Kazakhstan metals trading amid Russia sanctions”, 12 March 2026). In addition, Trafigura is actively involved in metals trading through Kazakh intermediaries, which enables circumvention of restrictions on direct supplies from Russia.
The Kazakh authorities have repeatedly stated that the country’s territory must not be used to circumvent sanctions and have tightened transaction checks. Nevertheless, the growth of secondary risks has already led to an extension of payment terms to 45–60 days and the introduction of additional compliance procedures for all EAEU counterparties. This creates additional economic costs for Kazakh businesses and reduces the country’s attractiveness as a transit hub.
Unlike Kazakhstan, a number of Central Asian states (Uzbekistan, Tajikistan and Turkmenistan) have introduced stricter restrictions on the penetration of large Russian business and pay close attention to figures with pronounced political ties, including Alisher Usmanov. Such measures are aimed at minimising the risks of secondary sanctions and maintaining a balance in relations with the West (Foreign Policy Research Institute, “The Impact of Russia Sanctions on Central Asia”, December 2024). Uzbekistan, for example, revoked several OFAC general licences for transactions involving Russian assets after 2022 and introduced additional checks for Russian investors. Turkmenistan and Tajikistan went even further, virtually closing access to strategic sectors for sanctioned entities.
Particular attention should be paid to the activities of young Kazakh businessmen who are closely integrated into Russian elite circles. Shakhmurat Mutalip (35, owner of Integra Construction KZ and President of the Boxing Federation of the Republic of Kazakhstan) is actively developing projects in construction and mining. According to media reports, he is seeking to acquire stakes in Kazzinc (Glencore) and up to 40 per cent of Eurasian Resources Group (ERG, estimated at around USD 1.4 billion). His personal ties with the management of VTB and Sberbank have also been reported, which, according to experts, could create channels of influence extending beyond purely commercial relations (The Insider, “Eurasian Resources Group could lose its OFAC licence…”, 13 January 2026; MK Kazakhstan, “Who is Shakhmurat Mutalip and why is his name linked to Russian banks”, 5 February 2026).
Mutalip, who previously focused on railway and motorway construction, sharply expanded his presence in mining in 2025–2026 by registering new companies at the Astana International Financial Centre (KazZinc Group Ltd and Central Asia Resources Holding Ltd). According to analysts, these steps reflect not only commercial interests but also a potential role as a proxy for Russian financial and industrial groups (Bloomberg, “Glencore Said to Close In on Sale of Kazzinc Mining Operations”, 19 February 2026).
Historical precedents (Mukhtar Ablyazov in Kazakhstan and the business structures of the Viktor Yanukovych era in Ukraine) demonstrate a typical trajectory: an initial focus on commercial projects, followed by a transition to financing political forces and parties. Given the Kremlin’s long-term strategy of integrating the post-Soviet space, it would be advisable for the Kazakh authorities to apply enhanced due diligence to such proxy figures, particularly in strategic sectors (George W. Bush Presidential Center, “Strategic Corruption: Russia in Europe and Central Asia”, December 2025).
Overall, the tightening of EU and US secondary sanctions in 2025–2026 (including new restrictions on third countries under the 20th package) is making sanctions-evasion schemes increasingly costly and risky. For Kazakhstan, maintaining its reputation as a reliable partner requires further strengthening of compliance controls, diversification of foreign economic relations and enhanced monitoring of proxy structures closely linked to Russian elites. It is recommended to develop a national strategy to minimise the risks of secondary sanctions, including the creation of a specialised regulatory body to oversee re-exports and foreign investment in strategic sectors, as well as deeper cooperation with the EU and the United States within early-warning mechanisms. Only such an approach will allow Kazakhstan to preserve the economic benefits of regional integration without undermining the long-term sovereignty and international reputation of the Republic of Kazakhstan.