Exports to Central Asia and the Caucasus: which checks matter after the latest changes to EU sanctions
Exports to Kazakhstan, Uzbekistan, Kyrgyzstan, Georgia, Armenia or Azerbaijan have long been part of normal international business for many European companies. At the same time, EU sanctions against Russia and Belarus have significantly changed the requirements for such deliveries.
One important principle applies first of all: an export to Central Asia or the Caucasus is not automatically problematic. What matters is which goods are delivered, who the buyer and the actual consignee are, how the goods are to be used and which route they take to their final destination.
For certain technical products in particular, a careful check before transport has therefore become increasingly important.
Why deliveries to third countries are checked more closely
The EU has extended its measures to combat the circumvention of existing Russia sanctions in several sanctions packages. Most recently, the 21st sanctions package of July 2026 included further companies from third countries in the measures.
These include companies from Kazakhstan and Kyrgyzstan. However, this explicitly does not mean that deliveries to these countries are generally prohibited.
The background is rather that certain goods can be forwarded to Russia via third countries. For European companies, it is therefore not always enough to look only at the consignee stated on the invoice.
1. Check the goods and the commodity code
Every check should start with the goods themselves.
In addition to the correct commodity code, you need to check whether the product is subject to existing export restrictions. Particular attention is required for dual-use goods, electronic components, machines and machine parts, certain vehicles and vehicle parts, and technologies that can be used for industrial or military purposes, among others.
An industrial component that looks ordinary at first glance may be relevant under export control law because of its technical characteristics.
For sensitive goods, it should therefore be clarified before the transport is commissioned whether an export licence is required or whether special restrictions apply.
2. Check buyers, consignees and beneficial owners
It is not only the direct contractual partner that should be checked.
A meaningful sanctions check also includes the consignee of the goods, any intermediaries and the persons behind a company. Banks, service providers or other parties involved in the transaction may also be relevant.
Particular caution is required, for example, if a company was founded only recently, the goods ordered obviously do not fit the customer’s usual business or the ownership and shareholding structure cannot be traced.
Simply checking the company name is therefore not always enough when the risk is higher.
3. Establish the end use of the goods
One of the most important questions is: where and for what will the goods actually be used?
For certain products, an end-use statement may be useful or required. In it, the consignee confirms, for example, the final place of use and that the goods will not be passed on to Russia or Belarus.
Unusual order quantities can also be a reason to look more closely. If a small trader suddenly orders large quantities of specialised electronics or industrial components, the economic plausibility of the delivery should be checked.
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4. Observe the “No-Russia” clause
For certain sensitive goods, Article 12g of EU Regulation 833/2014 requires a contractual obligation to prevent re-export to Russia when exporting to certain third countries.
This applies in particular to sensitive goods, including the so-called Common High Priority Items.
Companies should therefore check whether a corresponding “No-Russia” clause is required in the purchase, supply or export contract for their goods.
Such a clause is not just a formality. For the goods concerned, appropriate contractual consequences for breaches must be provided for.
5. Check the transport route
The route is also part of the sanctions check.
An export from Germany to Kazakhstan, Uzbekistan or the Caucasus can take different corridors. Depending on the goods, transit via Russia or Belarus in particular may be legally relevant or ruled out.
Shippers and freight forwarders should therefore know before the transport starts which countries the shipment will actually pass through.
A short-notice change of route by the carrier can be problematic for sensitive goods.
For such shipments, the permitted route should therefore be clearly agreed with the transport service provider.
6. Do not forget the payment route
Even a delivery of goods that is permitted in principle can cause difficulties if payment is processed via a sanctioned bank or a problematic financial intermediary.
In recent years, the EU has repeatedly extended its financial sanctions and has also included financial institutions outside Russia in the measures.
Exporter and consignee should therefore clarify, ideally before dispatch, which banks will process the payment. This reduces the risk that goods are already on their way while the corresponding payment is blocked.
Which warning signs should be taken seriously?
Not every unusual transaction is automatically a breach of sanctions. However, several irregularities together can make a more in-depth check necessary.
These include, for example, an unknown intermediary without any recognisable economic reason, short-notice changes to the consignee or delivery address, unusually complicated payment routes, missing information on end use or a request to change the description of the goods or the commodity code on the documents.
A transport route that hardly makes economic sense should also be questioned.
What does this mean for transport planning?
For certain exports, sanctions checks and transport organisation can no longer be completely separated today.
The exporter remains responsible for ensuring that the export of its goods is permitted under export control law. At the same time, the freight forwarder needs sufficient and correct information to plan a suitable route and prepare the necessary transport and customs documents.
For transports to Central Asia and the Caucasus, we therefore recommend providing complete details of the goods, commodity code, sender, consignee, loading and unloading location and, where applicable, the end use as early as the request.
MARTIN Internationale Spedition GmbH organises FTL, LTL, express and special transports between Germany and the European Union as well as between Germany and Georgia, Armenia, Azerbaijan, Kazakhstan, Uzbekistan and other Central Asian countries.
When planning transports, we take into account the current routing and the respective transit and transport regulations. For goods that are sensitive under sanctions or export control law, the legal admissibility of the export should be conclusively checked by the exporter or the competent authority before the transport starts.
