On February 23 the U.S. government published a new package of sanctions, which this time included not only Russian enterprises, but also companies from Kazakhstan, Uzbekistan and Kyrgyzstan.

The Ministry of Trade and Integration (MTI) of Kazakhstan said that the U.S. sanctions lists and a number of European countries included Elem Group LLP and Da Group 22 LLP. Elem Group LLP is registered as a company engaged in wholesale trade in electronic and telecommunications equipment and components. The LLP’s goods, such as microchips, analog-to-digital converters, and the like are known to be re-exported.

Da Group 22 was founded in 2022 and is a small business. Officially, the organization is engaged in wholesale trade of electronic and telecommunication equipment and its related componentry, and tax deductions for the year on average exceed 173 million tenge (~$385,000). The MTI noted that the companies’ entry into the restricted lists was known in advance. “Kazakh companies have previously [been in] dialogue with external partners and expressed their interest in continuing cooperation,” said the MTI’s press service.

It’s also been clear that neither Elem Group LLP nor Da Group 22 LLP carried out any import and/or export trade since 2023. Moreover, Elem Group LLP is currently in the process of liquidation.

Representatives of the MTI specified that Kazakhstani companies do not apply any sanctions towards Russia, but also try to avoid using their resources to circumvent Western sanctions.

A Kyrgyz privately held company, UKON, also found itself on the new U.S. sanctions list. According to the Ministry of Justice of Kyrgyzstan, UKON was registered in August 2022, and its sole founder and manager is Mehti Gafar-Zade (aka Mehti Fikret).

This is not the first company from Kyrgyzstan to be blacklisted by the U.S. for helping Russia circumvent sanctions. Last year, the companies Weitmann Handeln Allianz LLC, Tro.Ya, RM Design and Development, GTME Technologies, Progress Leader and Cargoline also fell under sanctions.

The State Committee of National Security of Kyrgyzstan stated that neither the state nor any state structures or companies intentionally contribute to the violation of compliance regimes stemming from sanctions imposed on Russia. The special service also noted that private companies on the sanctions lists may not have known who the end users of their products were — and thus may have been unknowingly involved in the supply of sanctioned goods to Russia.

Among others, a company from Uzbekistan, Mvizion, has fallen under the restrictions. In November 2023 it had already fallen under US sanctions, and in December the UK also blacklisted it.

Mvizion characterizes its activity as wholesale of electronic and telecommunication equipment and spare parts. It was registered in June 2022 in the name of Igor Ivlev.

Last summer, a number of European countries had already imposed sanctions on Uzbek companies Alfa Beta Creative and GFK Logistic Asia. Two months before that, the U.S. Treasury Department imposed restrictions against them for purchasing goods for the Russian defense industry in circumvention of sanctions.

The new U.S. sanctions list, which was published on February 23, 2024, includes the transport company Polar Star Logistics with an office in Tashkent, as well as Uzbek-born Maxim Zagornov, president of the Russian Small Energy Association and director of the Trade House of Business Russia in the UAE.