SANCTIONS & TRADE COMPLIANCE \u00a0\u00b7\u00a0 KAZAKHSTAN<\/p>\n
Bond Stone advises Kazakhstan-based companies and foreign investors on secondary sanctions risk \u2014 the extraterritorial reach of US OFAC, EU, and UK sanctions that affects Kazakhstan entities even where no direct sanctions apply. Kazakhstan has been explicitly identified by OFAC and the EU as a jurisdiction of concern for Russia sanctions evasion, with multiple Kazakhstani entities listed on US and EU sanctions lists since 2022.<\/p>\n
What are secondary sanctions<\/p>\n
Secondary sanctions are penalties imposed by the US, EU, or UK on non-US\/EU\/UK persons who conduct transactions with sanctioned parties or sectors \u2014 even where those transactions have no US, EU, or UK nexus. For Kazakhstan, the most significant secondary sanctions risk arises from OFAC’s Executive Orders 14024 and 14114, which authorise secondary sanctions against foreign financial institutions and entities that conduct or facilitate significant transactions with sanctioned Russian entities, sectors, or the Russian financial system.<\/p>\n<\/div>\n
OFAC EO 14024 and EO 14114 \u2014 Kazakhstan exposure<\/p>\n
Executive Order 14024 (April 2021) authorises OFAC to impose blocking sanctions on non-US persons who materially support sanctioned Russian entities. EO 14114 (December 2023) added a new Section 11 to EO 14024, authorising secondary sanctions against foreign financial institutions that facilitate significant transactions involving Russia’s military-industrial base or SDN-designated persons. OFAC used this authority in January 2025 to designate a Kyrgyz bank involved in Russia sanctions evasion \u2014 establishing a direct regional precedent for Central Asian financial institutions. A Kazakhstan company that trades with, finances, or provides services to an OFAC SDN-listed Russian entity risks being designated under EO 14024 \u2014 and losing access to the US financial system and USD correspondent banking.<\/p>\n<\/div>\n
EU sanctions circumvention \u2014 Article 8a<\/p>\n
The EU’s Russia sanctions include anti-circumvention provisions that prohibit EU persons from participating in activities designed to circumvent EU sanctions. From the 8th package (2022) onwards, EU sanctions also impose due diligence obligations on EU companies trading with partners in third countries identified as high circumvention risk \u2014 including Kazakhstan. EU companies trading through Kazakhstan entities must conduct enhanced due diligence on the ultimate destination of goods and services.<\/p>\n<\/div>\n
UK secondary sanctions \u2014 February 2025<\/p>\n
In February 2025, the UK used new designation powers to sanction entities in Kazakhstan, China, India, Germany, and Turkey identified as enablers and suppliers to the Russian defence sector. UK sanctions against non-UK persons are less broad than OFAC secondary sanctions in their direct reach, but create significant practical risk for entities seeking access to UK financial services, correspondent banking through UK-regulated institutions, or transactions with UK counterparties.<\/p>\n<\/div>\n
Correspondent banking \u2014 practical impact<\/p>\n
The most immediate practical risk for Kazakhstan companies is correspondent banking. US-regulated banks acting as correspondents for Kazakhstan banks conduct sanctions screening on all transactions routed through them. A transaction that triggers a match against OFAC SDN, EU, or UK sanctions lists \u2014 even a false positive \u2014 may result in payment blocking, account review, or de-risking of the Kazakhstan bank relationship. Bond Stone advises on compliance frameworks designed to reduce correspondent banking risk.<\/p>\n<\/div>\n<\/div>\n
Sanctions Screening \u2014 Trading Company<\/p>\n
Secondary Sanctions \u00b7 Kazakhstan \u00b7 Trade<\/p>\n
Advising a Kazakhstan trading company on OFAC and EU sanctions screening of its counterparty relationships \u2014 identifying SDN-list matches, assessing secondary sanctions exposure, and implementing a real-time counterparty monitoring protocol.<\/p>\n<\/div>\n
Correspondent Bank Query Response<\/p>\n
Secondary Sanctions \u00b7 Kazakhstan \u00b7 Banking<\/p>\n
Preparing a sanctions compliance response for a Kazakhstan company subject to a correspondent bank query \u2014 documenting KYC\/CDD framework, trade flows, and counterparty screening results to demonstrate absence of sanctioned party relationships.<\/p>\n<\/div>\n
M&A \u2014 Target Sanctions Review<\/p>\n
Secondary Sanctions \u00b7 Kazakhstan \u00b7 M&A<\/p>\n
Secondary sanctions due diligence on a Kazakhstan M&A target \u2014 reviewing counterparty relationships, beneficial ownership, and trade flows against OFAC SDN, EU Consolidated, and UK sanctions lists, and assessing post-acquisition compliance obligations.<\/p>\n<\/div>\n<\/div>\n
Why Bond Stone<\/p>\n
\u2726 \u00a0Kazakhstan market knowledge combined with US, EU, and UK sanctions extraterritorial reach expertise<\/p>\n
\u2726 \u00a0Ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader \u2014 Almaty and Astana offices<\/p>\n<\/div>\n
Contact Bond Stone for a confidential discussion about secondary sanctions risk in kazakhstan.<\/p>\n
\ud83d\udce7 info@bondstonelaw.com<\/a> Request a Confidential Consultation<\/a> SANCTIONS & TRADE COMPLIANCE \u00a0\u00b7\u00a0 KAZAKHSTAN Secondary Sanctions Risk in Kazakhstan Bond Stone advises Kazakhstan-based companies and foreign investors on secondary sanctions risk \u2014 the extraterritorial reach of US OFAC, EU, and UK sanctions that affects Kazakhstan entities even where no direct sanctions apply. Kazakhstan has been explicitly identified by OFAC and the EU as […]<\/p>\n","protected":false},"author":4,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-4893","page","type-page","status-publish","hentry"],"translation":{"provider":"WPGlobus","version":"3.0.3","language":"ru","enabled_languages":["en","ru"],"languages":{"en":{"title":true,"content":true,"excerpt":false},"ru":{"title":false,"content":false,"excerpt":false}}},"_links":{"self":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/4893","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/users\/4"}],"replies":[{"embeddable":true,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/comments?post=4893"}],"version-history":[{"count":2,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/4893\/revisions"}],"predecessor-version":[{"id":4908,"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/pages\/4893\/revisions\/4908"}],"wp:attachment":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/media?parent=4893"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
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