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Surge in Serbian exports to Kyrgyzstan raises concerns of sanctions evasion amidst Russia-Ukraine conflict

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The increase in Serbia’s exports to Kyrgyzstan, especially in the wake of the Russian invasion of Ukraine, raises significant concerns about potential sanctions evasion. Here are the key points from the report:

  1. Export growth: Serbian exports to Kyrgyzstan surged from $12.8 million in 2022 to $81.1 million in 2023. This is a sixfold increase within a year.
  2. Re-exporting concerns: There is a discrepancy between Serbian export figures and Kyrgyz import data. While Serbia reports $30 million in exports to Kyrgyzstan during a four-month period in 2023, Kyrgyzstan reported only $1 million in imports from Serbia. This discrepancy suggests that goods may be re-exported from Kyrgyzstan to other markets, possibly including Russia.
  3. Sanctioned goods: Among the goods exported are items on the EU and US sanctions lists, such as dual-use goods that can be used in military applications. Serbia’s exports of these sanctioned goods to Kyrgyzstan rose from $340,000 in 2022 to $7.7 million in 2023.
  4. Control issues: The Government of Serbia and the Ministry of Trade have not clarified if Kyrgyzstan is a transit point for goods circumventing sanctions. Similarly, Kyrgyzstan’s Statistical Committee has not published detailed import data, and the Deputy Prime Minister of Kyrgyzstan criticized claims of sanctions violations, stating they cannot control all dubious businesses.
  5. International oversight: The European Commission is closely monitoring these developments, emphasizing that evasion of sanctions through third countries is a priority concern. They stress cooperation with third countries to prevent such circumvention.
  6. Eurasian Economic Union: Kyrgyzstan’s membership in the Eurasian Economic Union complicates the monitoring of goods flow, as it allows for easier trade with Russia and other member states without stringent checks.

This situation underscores the challenges in enforcing international sanctions and the need for effective oversight and cooperation among nations to prevent circumvention.

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