KYRGYZSTAN · CUSTOMS AND SANCTIONS

EAEU Customs and Sanctions in Kyrgyzstan

Kyrgyzstan is a member of the Eurasian Economic Union. Goods from outside the Union pay the common EAEU customs duty and 12% import VAT when they enter Kyrgyzstan, and then move to Russia, Kazakhstan, Belarus and Armenia without customs declaration. That free movement is also why Western sanctions authorities treat Kyrgyzstan as a re-export risk. Since 24 April 2026 the EU has banned the sale of certain metal-working machining centres and data-routing equipment to anyone in Kyrgyzstan, and has prohibited transactions with two Kyrgyz banks from 14 May 2026 and with a third from 13 August 2026. The United States designated Keremet Bank in January 2025, and the United Kingdom designated it, with another Kyrgyz company, in February 2025.

This page covers the customs union rules, import taxes, free economic zone customs regimes, Kyrgyz export controls, and the US, EU and UK measures that affect companies trading in or through Kyrgyzstan. For VAT and profit tax see Tax in Kyrgyzstan.

Legal framework

What EAEU membership means for goods

Within the customs union, the member states have an internal market for goods, apply the Common Customs Tariff and other common measures to trade with third parties, apply single customs regulation, and move goods between their territories without customs declaration or state border controls, except as the Treaty provides (EAEU Treaty, Art. 25(1)). Customs regulation follows the EAEU Customs Code (Art. 32). The common commodity nomenclature and the Common Customs Tariff are approved by the Eurasian Economic Commission and apply across the customs territory (Art. 42(1)). A member state may still restrict mutual trade where necessary for, among other reasons, defence and state security or international obligations (Art. 29(1)).

Kyrgyzstan applies the Customs Code through its own Law on Customs Regulation, which governs the movement of goods across the EAEU customs border in Kyrgyzstan (Art. 1). The national law also sets the conditions for free warehouse owners (Arts. 225–229) and for authorised economic operators, which obtain special simplifications (Arts. 235–245).

Import duties and VAT

In mutual trade, indirect taxes follow the destination principle: exports to another member state are zero-rated and imports are taxed in the country of import (EAEU Treaty, Art. 72(1)). A Kyrgyz importer from Kazakhstan or Russia therefore pays VAT to the Kyrgyz tax service, not at the border.

Free economic zones and the free customs zone procedure

Under the Customs Code, the free customs zone procedure lets foreign goods and EAEU goods be placed and used in a special economic zone without customs duties, taxes, or special, anti-dumping and countervailing duties, if the conditions of the procedure are met (Art. 201(1)). Goods are placed under it for use by zone entities under their agreement on the conditions of activity in the zone (Art. 201(2)), and almost any operation may be performed with them in the zone, including storage, processing, manufacture, assembly and repair (Art. 205(1)).

The Kyrgyz Law on Free Economic Zones applies the procedure on the zone territory, or the part of it fitted out for customs control (Art. 14(2)–(3)). Foreign goods placed under it are treated as outside the EAEU customs territory for duties, taxes and tariff and non-tariff measures (Art. 14(6)). Goods leaving the zone for the rest of Kyrgyzstan are taxed and subject to tariff and non-tariff measures (Art. 14(9)), and sales of zone-made goods into Kyrgyzstan are subject to a quota set by the Cabinet, with tax due on the excess (Art. 14(11)). Exports of zone-made goods to the EAEU and to third countries are free from quotas (Art. 14(11)). A zone entity pays the general directorate an annual fee of 0.5% to 2% of revenue, or 0.1% to 2% in zones created for accelerated regional development (Art. 6(9)). The Naryn zone is designated for the special features of the free customs zone procedure in Article 455 of the Customs Code (Law on Free Economic Zones, Art. 4(2)).

A zone entity that fails the fencing and customs control requirements falls under the general tax regime (Art. 6(3)). Zone status is lost or withdrawn on the grounds in Article 12, including repeated tax or customs breaches confirmed by courts and twelve months without activity. For land in the zones see Real Estate and Land in Kyrgyzstan.

Kyrgyz export controls

The Law on Export Control covers foreign trade in controlled products across all of Kyrgyzstan, including the free economic zones (Art. 2). Controlled products are those on the National Control List approved by the Cabinet of Ministers, and identifying whether goods are on the list is the trader's duty (Art. 6). Exports and re-exports of dual-use goods to a foreign person require an end-user certificate and a written undertaking that the goods will not be used for weapons of mass destruction or re-exported without the authorised body's consent (Art. 10). Traders must keep records of transactions in controlled products and provide them on request (Art. 9).

Re-export and sanctions risk

The measures below are adopted by the United States, the European Union and the United Kingdom, not by Kyrgyzstan. In adding Kyrgyzstan to the EU anti-circumvention annex, the Council noted that imports of common high priority items from the EU into Kyrgyzstan were almost 800% higher, and exports of such items from Kyrgyzstan to Russia 1,200% higher, than before the war, and identified Kyrgyzstan as a jurisdiction where the risk of circumvention is systematic and persistent (Regulation (EU) 2026/506, recitals 34 and 35).

European Union

• Anti-circumvention listing. Article 12f of Regulation 833/2014 prohibits selling, supplying, transferring or exporting the goods in Annex XXXIII, wherever they originate, to any person in the third country named there, and related technical assistance, brokering, financing and IP licensing. Council Regulation (EU) 2026/506 of 23 April 2026 named the Kyrgyz Republic for CN 8457 10 (machining centres for working metal) and CN 8517 62 (machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus).
• Bank transaction ban. Article 5ad prohibits transactions with listed credit and financial institutions outside the EU. From 14 May 2026, Part B of Annex XLV lists Keremet Bank and OJSC Capital Bank of Central Asia, both in Kyrgyzstan, as institutions supporting Russia's war of aggression.
• Payment messaging ban. Article 5ac prohibits transactions with entities outside Russia listed in Annex XLIV as users of the Bank of Russia's financial messaging system or equivalent Russian systems. From 13 August 2026 Annex XLIV lists CJSC Eco-Islamic Bank in Kyrgyzstan (added by Regulation (EU) 2026/1848).
• Listed end users. Annex IV, the list of end users connected with Russia's military and industrial complex, includes companies with Bishkek addresses, several of them added on 24 July 2026 by Regulation (EU) 2026/1848.
• No-Russia clause. EU exporters of goods in Annexes XI, XX and XXXV, common high priority items in Annex XL, and listed firearms to any country other than the partner countries in Annex VIII must contractually prohibit re-export to Russia or for use in Russia, with adequate remedies, and report breaches (Art. 12g). Kyrgyzstan is not in Annex VIII.
• Due diligence. Sellers of common high priority items in Annex XL or goods in Annex XLVIII must assess and document the risk of export to Russia and have policies and controls to manage it (Art. 12gb). EU persons must use best efforts to ensure that entities they own or control outside the EU do not undermine the Regulation (Art. 8a).

United States

On 15 January 2025 OFAC added OJSC Keremet Bank of Bishkek to the Specially Designated Nationals List under Executive Order 14024, as amended by Executive Order 14114, for conducting or facilitating significant transactions or providing services involving Russia's military-industrial base. Treasury's press release stated that the bank's officials had coordinated with Russian officials, and that the purchase of a controlling stake sold by the Kyrgyz Ministry of Finance was intended to create a sanctions evasion hub for Russia to pay for imports and receive payment for exports. The SDN entry carries a secondary sanctions risk notice referring to Section 11 of Executive Order 14024. Treasury also warned that foreign financial institutions that conduct or facilitate significant transactions involving Russia's military-industrial base risk being sanctioned. The SDN List also includes other companies registered in Kyrgyzstan under the same Russia-related programme, so screening should cover counterparties as well as banks.

United Kingdom

On 24 February 2025 the UK government's list of new Russia sanctions targets included OJSC Keremet Bank, under the heading "Foreign Financial Institution", as a Kyrgyzstan-based bank linked to the Russian financial services sector, and Rama Group LLC, as a Kyrgyzstan-based company that has exported microelectronics to Russia. The designations were made under the Russia (Sanctions) (EU Exit) Regulations 2019. On the UK Sanctions List as published on 3 November 2026, both are subject to an asset freeze, trust services sanctions and director disqualification, and Keremet Bank also to a prohibition on correspondent banking and clearing. Rama Group was also added to the EU's Annex IV in July 2026. Check the current UK Sanctions List for the measures that apply to each entry.

Managing the risk: step by step

1. Map the flows

Identify which goods move from the EU, UK or US into Kyrgyzstan, and where they go after import, including onward EAEU sales that require no customs declaration.

2. Classify the goods

Check CN or HS codes against EU Annexes XXXIII and XL and the Kyrgyz National Control List. Classification decides whether an export to Kyrgyzstan is banned outright or needs controls.

3. Screen counterparties and banks

Screen customers, intermediaries and banks against the SDN List, the EU lists including Annexes IV, XLIV and XLV, and the UK list. Payments through a listed Kyrgyz bank are a direct exposure for EU, UK and US persons.

4. Contract for compliance

Include the Article 12g no-Russia clause where it applies, end-use statements, audit rights and termination on breach.

5. Obtain Kyrgyz licences where needed

Dual-use exports, re-exports and transits need a licence or permit from the Ministry of Economy and Commerce; build in the 15 working days for a decision.

Common mistakes foreign investors make

• Treating EAEU access as sanctions-neutral. Goods move on to other member states without customs declaration, and the EU has named Kyrgyzstan as a systematic and persistent circumvention risk for listed goods.
• Relying on the end customer's word. Article 12g requires a contractual prohibition with remedies, and Article 12gb requires documented risk assessment.
• Overlooking the banking channel. EU persons may not transact with the Kyrgyz banks in Annexes XLIV and XLV (Arts. 5ac, 5ad), and Keremet Bank is on the US SDN List and the UK Sanctions List.
• Using a free economic zone for domestic sales without checking the quota. Zone-made goods sold into Kyrgyzstan above the quota are taxed.
• Assuming export controls apply only at the border. The Kyrgyz law applies inside free economic zones and to transfers within the country.

Frequently Asked Questions

Do goods imported into Kyrgyzstan pay EAEU duties?

Goods from outside the Union pay duty at the Common Customs Tariff rate and 12% import VAT. Goods from another EAEU member state pay no duty and are not declared at the border, but the importer pays 12% VAT to the tax authority by the 20th of the following month.

Has the EU sanctioned Kyrgyzstan?

The EU measures are targeted. Under Regulation 833/2014 the EU bans sales of two categories of goods to anyone in Kyrgyzstan (Art. 12f and Annex XXXIII), prohibits transactions with two Kyrgyz banks from 14 May 2026 (Art. 5ad and Annex XLV) and a third from 13 August 2026 (Art. 5ac and Annex XLIV), and lists some Kyrgyz companies as restricted end users (Annex IV).

Can a Kyrgyz company be hit by US secondary sanctions?

Yes. OFAC designated Keremet Bank under Executive Order 14024 as amended by Executive Order 14114, and Treasury has warned that foreign financial institutions facilitating significant transactions for Russia's military-industrial base risk sanctions.

What is the free customs zone procedure?

It lets zone entities hold and process foreign goods in a free economic zone without customs duties and taxes (Customs Code, Art. 201). Goods leaving the zone into Kyrgyzstan are taxed and sales into Kyrgyzstan are subject to a quota (Law on Free Economic Zones, Art. 14).

Who issues Kyrgyz export licences for dual-use goods?

The Ministry of Economy and Commerce, which decides within 15 working days of registering a complete application. Military goods are licensed by the Ministry of Defence (Export Control Regulation, paras. 11, 12, 29).

Bond Stone's Bishkek office advises foreign investors on EAEU customs regimes, free economic zones, export licensing and sanctions screening for business in Kyrgyzstan.

Related pages

Kyrgyzstan Legal Guide  ·  Tax in Kyrgyzstan  ·  Investment Protection and Disputes in Kyrgyzstan  ·  Real Estate and Land in Kyrgyzstan  ·  Secondary Sanctions Risk in Kazakhstan  ·  Export Controls and Dual-Use Goods in Kazakhstan  ·  Legal Services in Kyrgyzstan

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Primary sources: cbd.minjust.gov.kg — Law No. 52 on Customs Regulation (Arts. 1, 225–229, 235–245); Tax Code No. 3 (Arts. 254, 310, 311, 320); Law No. 6 on Free Economic Zones (Arts. 4, 6, 12, 14); Law No. 30 on Export Control (Arts. 2, 6, 9, 10); Cabinet Resolution No. 573 of 13 September 2024 (paras. 11, 12, 29, 41, 52); Law No. 223 of 30 December 2017. Treaty on the Eurasian Economic Union (Arts. 25, 29, 32, 42, 72); Customs Code of the EAEU (Arts. 201, 205, 455). Council Regulation (EU) 2026/506, Council Regulation (EU) 2026/1848 and Regulation (EU) No 833/2014, consolidated to 24 July 2026 (Arts. 5ac, 5ad, 8a, 12f, 12g, 12gb; Annexes IV, VIII, XXXIII, XLIV, XLV). OFAC recent actions, 15 January 2025; US Treasury press release JY2785. UK list of Russia sanctions targets, 24 February 2025; UK Sanctions List; OFAC SDN List.