US Export Administration Regulations (EAR)

The US EAR — administered by the Bureau of Industry and Security (BIS) — controls the export, re-export, and in-country transfer of items on the Commerce Control List (CCL). EAR jurisdiction extends to items of US origin anywhere in the world, regardless of where the exporting company is located. A Kazakhstan company importing US-origin goods and re-exporting them — directly or indirectly — to a sanctioned destination or an entity on the BIS Entity List violates the EAR and exposes the company’s US suppliers to enforcement action, and potentially the Kazakhstan company itself to denial of US export privileges.

BIS Entity List — Kazakhstan entities

The BIS Entity List identifies specific companies and individuals subject to licence requirements for all items subject to EAR. Multiple Kazakhstan entities have been added to the BIS Entity List since 2022 for alleged involvement in supplying controlled goods to Russia. A Kazakhstan company on the Entity List is effectively cut off from US-origin components, software, and technology — a significant operational constraint for companies in electronics, industrial equipment, and technology sectors. Bond Stone advises on Entity List assessment, licence applications, and compliance remediation.

EU dual-use goods — Regulation 2021/821

EU Regulation 2021/821 controls the export of dual-use items — goods, software, and technology that have both civilian and military applications. The EU has significantly expanded its dual-use controls in the context of Russia sanctions, adding new items and tightening re-export restrictions. A Kazakhstan company importing EU-origin dual-use goods and re-exporting them must ensure compliance with EU re-export controls — and EU exporters are required to conduct due diligence on the ultimate destination of dual-use goods exported to Kazakhstan.

Kazakhstan’s export control framework

Kazakhstan maintains its own export control framework — the Law on Export Control of Weapons and Military Equipment and related subordinate legislation — which controls the export of military goods, dual-use items, and goods subject to international treaties. Kazakhstan is a member of several international export control regimes. Bond Stone advises on Kazakhstan export licence requirements for controlled goods and compliance with Kazakhstan’s domestic export control obligations alongside international requirements.

End-user certificates and due diligence

A key tool in export control compliance is the end-user certificate (EUC) — a document provided by the importing company or its government confirming the intended end use and end user of controlled goods. Western export control authorities increasingly require EUCs from Kazakhstan importers as a condition of export licence approval. Bond Stone advises on preparing and submitting EUC documentation and implementing end-user screening protocols.

EAR Compliance Assessment — Industrial Importer

Export Controls · Kazakhstan · Industrial

Advising a Kazakhstan industrial company importing US-origin components on EAR compliance — classifying goods against the Commerce Control List, assessing licence requirements, and implementing an end-user screening protocol to prevent inadvertent EAR violations.

BIS Entity List — Advisory

Export Controls · Kazakhstan · Technology

Advising a Kazakhstan technology company on BIS Entity List risk — reviewing its US-origin technology supply chain, identifying Entity List exposure among suppliers and customers, and advising on licence applications and alternative sourcing strategies.

EU Dual-use — Re-export Assessment

Export Controls · Kazakhstan · Trade

Advising on EU dual-use goods re-export compliance for a Kazakhstan trading company — assessing whether goods imported from EU suppliers require re-export authorisation for onward shipment within the EAEU, and implementing an EU dual-use compliance framework.