Sanctions - The Times Of Central Asia

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Sanctions

Iran Sanctions and European Energy Security: Compliance Considerations for Caspian Trade

On February 6, 2026, the United States announced a new round of sanctions targeting Iranian petroleum shipping networks, designating 15 entities, two individuals, and 14 vessels involved in transporting Iranian oil and petroleum products in circumvention of existing restrictions. Taken pursuant to existing executive authorities and aligned with National Security Presidential Memorandum-2 (NSPM-2), the measures reflect an intensified U.S. enforcement focus on maritime intermediaries and logistics networks, including Iran’s “shadow fleet.” While the sanctions target Iranian petroleum trade, they reinforce existing risk considerations in shared maritime spaces where sanctioned and non-sanctioned trade operate in proximity, including jurisdictions in formal compliance with U.S. and international sanctions regimes. The recent announcement is an extension of the U.S. Treasury’s existing sanctions measures against Iranian petroleum shipping and associated logistics networks, with implications for compliance and due-diligence processes. It does not impact lawful energy exports and commercial trade via the Caspian Sea that involve other littoral states including Kazakhstan, Azerbaijan, or Turkmenistan, whose energy exports and financial institutions operate in compliance with applicable Office of Foreign Assets Control (OFAC) regulations. Recent additions to the Specially Designated Nationals (SDN) List include individuals and entities linked to 18 jurisdictions including the United Kingdom, Turkey and the UAE, with one entity co-domiciled in Kazakhstan and Georgia, the latter being a corridor country bordering Azerbaijan. As Central Asia’s largest oil and gas producer, Kazakhstan relies heavily on the Caspian Sea as a critical route for energy exports and associated cargo. While most Kazakh crude reaches global markets via pipelines, the Caspian remains essential for regional trade connectivity, particularly through the port of Aktau and related terminals. Kazakhstan is also a significant supplier of crude oil to European markets, contributing to the continent’s diversification away from Russian energy sources and making the reliability of its export routes relevant to European energy security. Kazakhstan’s exposure to sanctions risk in the Caspian Sea is fundamentally structural rather than policy-driven and is shared with other non-sanctioned shoreline states, namely Azerbaijan and Turkmenistan. Bordered by Russia and Iran—both of whom are heavily sanctioned by the U.S. and EU— the Caspian’s shared maritime space places regional infrastructure in an operating environment where vessels, cargoes, and service providers may be indirectly affected by international restrictions on Russian and Iranian trade. These spillover risks extend across the basin regardless of the compliance posture of individual entities or the policy intent and regulatory efforts of the host states. Recent U.S. policy developments, including NSPM-2, have increased the relevance of these structural conditions by clarifying enforcement priorities under existing sanctions authorities with a focus on the conduct of non-sanctioned actors whose activities may be seen as facilitating sanctioned revenue generation. Enforcement practice emphasizes facilitation, awareness, and the adequacy of compliance controls—and increasingly encompasses maritime intermediaries such as ports and port operators, shipping companies, transshipment facilities, insurers, financiers, and other logistics service providers. As a result, Caspian transit pathways may face heightened compliance and due-diligence expectations in certain scenarios, even when handling non-sanctioned cargo for lawful trade. Operational indicators...

Banking

Kazakhstan’s Banking System and the Logic of Early Enforcement

Kazakhstan’s growth model depends on uninterrupted access to international finance. Because its largest energy and mining projects rely on foreign capital, hard-currency financing, and offshore banking channels, confidence in the integrity of its banking system is not just a regulatory issue; it is a macroeconomic constraint. This reliance is structural. Export revenues are concentrated in globally-priced commodities—especially oil (up to 60% of total exports in recent years), and uranium (40%+ of global output)—linking fiscal stability directly to hard-currency liquidity and correspondent banking access. In that context, correspondent banking is a systemic requirement underpinning international payments and trade. Because international banks incorporate sanctions exposure and AML/CFT risk into their assessments, adverse risk perceptions can trigger de-risking behavior that raises costs and slows flows. Astana is now courting U.S. and European investment in multibillion-dollar initiatives, including the Trans-Caspian/Middle Corridor and projects related to rare earth and critical minerals supply chains. This further increases Kazakhstan’s exposure to Western compliance standards and regulatory scrutiny. With a growth model heavily driven by foreign capital, Kazakhstan understands that perceived weaknesses in banking system compliance would not halt investment outright, but would translate into higher funding costs and reduced appetite in international capital markets. Sanctions Exposure After 2022: Structural, Not Tactical Russia’s full-scale invasion of Ukraine in February 2022 sharply increased Kazakhstan’s exposure to global sanctions enforcement. Geography, membership in the Eurasian Economic Union, and dense trade and infrastructure ties with Russia made Kazakhstan a focal point for concerns over re-exports and sanctions leakage. At the same time, its border with China—an important source of dual-use goods—has added another layer of scrutiny, even as reporting later showed that China-origin cargo bound for Russia was, in documented cases, routed without physically entering Kazakhstan, despite being linked to it in trade flows. Western sanctions reshaped logistics faster than enforcement capacity could adapt. Restrictions on shipping, insurance, and financial services increased reliance on overland transit routes through Central Asia, drawing attention to Kazakhstan, even where violations were difficult to substantiate. Western investigations later showed that EU-origin dual-use goods continued to reach Russia through intermediary channels, underscoring enforcement gaps beyond Kazakhstan itself. For Kazakhstan, however, heightened scrutiny translated directly into financial risk, regardless of intent. In the logic of global compliance, perception can be as consequential as proof. Early Intervention as Risk Management Since 2022, Kazakhstan’s response has evolved from declaratory neutrality to early, containment-oriented enforcement. This shift has been driven less by foreign-policy alignment than by a calculation that even isolated violations can carry disproportionate financial consequences. President Kassym-Jomart Tokayev has repeatedly emphasized that sanctions violations carry direct economic consequences for Kazakhstan, warning in public remarks that non-compliance could expose the country to secondary sanctions affecting trade, finance, and investment flows. By framing compliance as a matter of macroeconomic risk management rather than geopolitical positioning, the government signaled that enforcement would prioritize financial stability over short-term commercial convenience. That logic has translated into practice. When Western sanctions were imposed on Sberbank in 2022, Kazakhstan approved the sale and restructuring of...

Alisher Usmanov

German Court Restricts Media Claims About Russian-Uzbek Billionaire Alisher Usmanov

A German court has ruled in favor of Russian-Uzbek billionaire Alisher Usmanov, barring the publication of several contested statements made about him by the Frankfurter Allgemeine Zeitung (FAZ), according to court documents cited by Reuters. In a decision dated January 23, the Hamburg Regional Court prohibited FAZ from further disseminating specific sections of its April 2023 article titled On the Kremlin’s Instructions. The statements in question allegedly linked Usmanov to senior Russian officials. The court determined that these claims may no longer be repeated in their current form. Usmanov, who was born in Uzbekistan, has an estimated net worth of $18.8 billion, according to the Bloomberg Billionaires Index. He is subject to European Union and United States sanctions, including a travel ban, imposed following the start of the war in Ukraine. Over the past two years, he has launched multiple legal challenges in European courts, contesting media reports that he argues were used as justification for the sanctions. Reacting to the ruling, Usmanov’s lawyer, Joachim Steinhöfel, said the statements banned by the court “repeated essential parts of the reasoning behind the sanctions against Mr. Usmanov.” He added that the decision supports the argument that the sanctions were based on what he described as “defamatory and groundless allegations,” Reuters reported. FAZ said it is considering an appeal. A spokesperson for the newspaper warned that the court’s legal criteria could make it more difficult to report on individuals in authoritarian systems, raising broader concerns about press freedom. Separately, in 2024, another Hamburg court ruled against the German broadcaster ARD over a report that linked Usmanov to a scheme involving alleged bribes to judges at the International Fencing Federation. The court banned further distribution of the report, describing it as “news based on suspicion.” Violations of the order could lead to fines of up to €250,000 per incident or imprisonment. Reuters also reported that German authorities agreed last month to close a foreign trade law investigation involving Usmanov after he paid €10 million. A separate money laundering probe was dropped in 2024.

Sanctions

UK Adds Uzbekistan-Based Companies and Tashkent Businessman to Russia Sanctions List

Britain has expanded its Russia sanctions regime to include four companies based in Uzbekistan and one Tashkent-born businessman, according to official documents published on 18 December 2025. The measures form part of a wider update that added 24 new individuals and entities to the UK’s consolidated sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019. The update was set out in a Financial Sanctions Notice issued by HM Treasury and an accompanying Foreign Office policy paper, “List of Russia sanctions targets, 18 December 2025.” The documents confirm that all newly designated names are now subject to an asset freeze and associated financial restrictions in the UK. The four Uzbekistan-linked companies named in the notice are Fargona Kimyo Zavodi LLC, also listed under the English alias Fergana Chemical Plant; Gelion Business Trade MCHJ, registered in Tashkent; Raw Materials Cellulose MCHJ, based in the Jizzakh region; and LLC JV Chemistry International, located in the Navoi region. Each company is subject to an asset freeze, requiring that any funds or economic resources they own or control in the UK be frozen and that UK persons do not make funds or resources available to them without a licence. The Treasury notice also applies restrictions on trust services. Under UK sanctions law, this restricts UK persons from providing trust services to or for the benefit of designated persons unless an exemption applies or a licence is granted. Compliance guidance is published by the Office of Financial Sanctions Implementation and linked through the British government’s Sanctions List. The documents do not provide detailed descriptions of the companies’ commercial activities, instead using standard statutory wording. In each case, the Secretary of State notes that there are reasonable grounds to suspect the entity “is or has been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine,” including by making available goods or technologies that could contribute to those outcomes. The sanctions update also includes Rustam Muminov, born in Tashkent in 1953. The Treasury notice lists his nationalities as Uzbek, Israeli, and Russian. Muminov is subject to an asset freeze and trust services restrictions, with the reason stated being that the British authorities have reasonable grounds to suspect he has been involved in destabilizing Ukraine by providing financial services or by making available funds, economic resources, goods, or technology. The Foreign Office policy paper groups the new designations with others added on the same date, which include entities linked to Russia’s energy sector, financial circumvention, and the military-industrial complex. The government says the measures are intended to limit access to financial services and resources that could support Russia’s actions against Ukraine.

Lukoil

Kazakhstan Yet to Decide on Potential Purchase of LUKOIL Assets

Kazakhstan holds the legal right of first refusal on any potential sale of LUKOIL's assets within its territory, but the authorities have not initiated negotiations to acquire them, Energy Minister Yerlan Akkenzhenov has said during a recent briefing. In October, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) expanded restrictions affecting Russian energy companies, including certain transactions involving LUKOIL and Rosneft, granting temporary licenses permitting specified transactions and wind-down activities until November 21. The United Kingdom also issued restrictions on October 15. In response, LUKOIL began exploring the sale of its foreign assets, including holdings in Kazakhstan. LUKOIL has maintained a presence in Kazakhstan since 1995. The company currently holds a 13.5% stake in Karachaganak Petroleum Operating B.V. (operator of the Karachaganak field), 5% of Tengizchevroil LLP (which develops the Tengiz field), 50% of Turgai Petroleum JSC (Kumkol field operator), and 12.5% of the Caspian Pipeline Consortium (CPC), the primary export route for Kazakh oil. However, several of LUKOIL’s international projects, such as its involvement in Tengiz and Karachaganak, as well as the CPC, have received exemptions from U.S. and UK sanctions. OFAC recently extended a license allowing negotiations and agreements related to the potential sale of LUKOIL International GmbH or other affiliated entities until January 17, 2026. Speaking at the briefing, Minister Akkenzhenov stated that Kazakhstan is not rushing to engage in any asset acquisition discussions. "The deadline has now been extended until mid-January, and we are all awaiting the conclusion of that period and any further developments. The government is not currently negotiating the purchase of these assets," Akkenzhenov said. "However, many companies around the world are interested, and I would like to remind everyone that Kazakhstan has priority rights under the Subsurface Code. We will decide in due course whether to exercise this right." Akkenzhenov also addressed the ongoing arbitration dispute over the Kashagan oil field, the largest in the Kazakh sector of the Caspian Sea. According to the minister, substantive legal proceedings are not expected to begin before the second half of 2026, with a more detailed review likely to follow in 2027. “Currently, the process is limited to collecting documents. It is premature to speculate on potential arbitration amounts, as the court has not yet accepted the case for detailed consideration,” he said. As previously reported by The Times of Central Asia, Kazakhstan’s arbitration claims against the NCOC consortium developing Kashagan, which includes Shell, ExxonMobil, TotalEnergies, and Eni, exceed $150 billion.

Oil and Gas

China’s Power Play in Central Asia’s Energy Sector

China is steadily expanding its influence in Central Asia’s oil and gas sector through multi-billion-dollar investments, long-term supply agreements, and a growing network of strategic partnerships. From Kazakhstan to Turkmenistan, Beijing’s state-backed companies are securing key upstream and midstream assets, financing new petrochemical and pipeline projects, and positioning themselves as indispensable players in the region’s resource development. This expansion is driven not only by China’s rising energy demand, but also by Beijing’s ambition to establish durable overland energy corridors that reduce reliance on maritime routes vulnerable to disruption. Central Asia’s existing and planned pipelines provide China with rare direct access to oil and gas fields across its western frontier, making the region a focal point of its broader energy-security strategy and a cornerstone of Beijing’s efforts to diversify supply while deepening political and economic footholds across Eurasia. Kazakhstan Eyes Chinese Investment Amid Lukoil Sanctions Kazakhstan may seek to transfer Russian company Lukoil’s stake in the offshore Kalamkas-Khazar oil and gas project to a new partner, with some industry channels, including the Telegram channel Energy Monitor, speculating about possible Chinese interest. Lukoil, which has been targeted by Western sanctions, is reportedly planning to exit Kalamkas-Khazar Operating LLP, a joint venture with KazMunayGas (KMG). Each company currently holds a 50% stake. Some commentators have suggested that a Chinese investor could step in, but no replacement has been officially confirmed. Seconded engineers from KMG Engineering are expected to be withdrawn from the project as of January 1, 2026, with several Kalamkas-Khazar staff members temporarily reassigned to other KMG subsidiaries until a new partner is confirmed. The project is considered highly promising, with earlier estimates citing reserves of 81 million tons of oil and 22 billion cubic meters of gas. New exploration has identified additional oil-bearing structures. A final investment decision (FID) worth more than $6.5 billion was originally expected by the end of 2025. However, U.S. sanctions against Lukoil have delayed progress. Located 120 km from the Kashagan field in the North Caspian Basin, the Kalamkas-Khazar block comprises the Kalamkas-More and Khazar fields. The site is situated in Kazakhstan’s Mangistau Region, 60 km from the Buzachi Peninsula. KazMunayGas Chairman Askhat Khasenov previously confirmed that production was expected to begin in 2028-2029, with peak output reaching four million tons annually. Lukoil was sanctioned by the UK on October 15, followed by the U.S., complicating ongoing negotiations. Despite this, major projects where Lukoil holds minority stakes, such as Tengiz, Karachaganak, and the Caspian Pipeline Consortium, have not been impacted. A Lukoil withdrawal would create a rare opening for China to secure its first significant offshore position in the North Caspian, a zone historically dominated by Western majors and Russian firms. Such an entry would represent a notable shift in Kazakhstan’s offshore partnership landscape. Beijing's Billion-Dollar Energy Deals in Kazakhstan In September 2025, President Kassym-Jomart Tokayev announced a series of energy deals with China valued at $1.5 billion. During his official visit to China, more than 70 commercial agreements totaling approximately $15 billion were signed, several...