Sanctions pressure from the EU and the U.S. on Russia continues to intensify, with growing implications for Kazakhstan’s economy. These measures threaten not only asset freezes but also civil and regulatory liability for transactions conducted through Western jurisdictions.
Kursiv.media spoke with Andris Ivanovs, an expert at the British law firm Ashurst, about how businesses can identify sanctions-related risks in Kazakhstan and the five essential steps they should take to protect themselves.
Key risks for Kazakhstani companies doing business with Russia
In October 2025, the EU adopted its 19th sanctions package, which directly affected several companies in Central Asia, including Kazakhstan.
According to Ivanovs, secondary U.S. sanctions pose the most serious threat. These sanctions allow penalties against any non-U.S. financial institution that conducts transactions with an entity listed on the U.S. Treasury Department’s Specially Designated Nationals (SDN) list, or with a company that is more than 50% owned by an SDN-listed entity.
The consequences can be severe. A violating institution itself may be added to the SDN list, effectively cutting it off from the U.S. financial system.
Where sanctions could expand next
Ivanovs identified two areas where further tightening is likely in the near future:
Third-country financial and crypto institutions: Increased scrutiny of banks and cryptocurrency service providers in «third countries» that facilitate trade in goods included on the common list of high-risk priority items.
Military-critical goods: Stricter controls on exports of products critical to Russian weapons systems, such as certain integrated circuits and advanced electronics.
Common compliance mistakes
One of the most frequent errors made by Kazakhstani companies, Ivanovs said, is underestimating the scope and complexity of Western sanctions regimes.
Companies often focus only on direct dealings with sanctioned parties, overlooking indirect exposure. However, sanctions can also apply to indirect violations. For example, a European supplier may still face liability if it sells goods to a Kazakh company that later re-exports those goods to Russia in violation of EU sanctions.
What a post-sanctions compliance checklist should include
To reduce exposure, Western regulators recommend that Kazakhstani companies implement a robust sanctions compliance program built around five core elements:
Management commitment
Senior leadership must set a clear «tone from the top,» demonstrating a commitment to sanctions-compliant business practices and active risk management.
Risk assessment
Companies should evaluate how U.S., EU and UK sanctions may apply to their operations, including the risk of facilitating sanctions circumvention, such as supplying goods to Russia’s military-industrial complex.
Internal policies and controls
Firms should develop internal policies tailored to their specific risk profile, appoint a responsible compliance officer and conduct regular employee training.
Due diligence
Counterparty checks should be documented and risk-based, covering ownership structures, directors and the ultimate end users of goods and services.
Ongoing monitoring and testing
Compliance programs must be reviewed regularly to reflect legal developments, and transactions should be tested to ensure procedures are consistently followed.
