DENMARK Trends and Developments Contributed by: Rikke Sonne, Jakob Skov Bundgaard and Tilde Nielsen Weidinger, Accura
controls on the re-exportation of sanctioned goods to Russia, and the EU expressed concern over “deliber - ate circumvention of our sanctions”. On 23 April 2026, the EU then activated its anti-circumvention tool for the very first time, as part of the 20th sanctions pack - age, on the grounds of a “systematic and persistent failure on the part of the Kyrgyz Republic to prevent the sale, supply, transfer or export to Russia” of cer - tain high-risk goods from the EU, including machine tools and telecommunications equipment used in the manufacture of drones and missiles in Russia. The decision followed a thorough analysis of trade data, which showed a significant increase in the re-exporta - tion via Kyrgyzstan to Russia of “common high-priority goods” – the category of items that the EU considers most critical to sustaining Russia’s weapons produc - tion, including certain electronics, machine tools and other dual-use components. In concrete terms, the activation entailed a ban on the exportation of computer numerical control (CNC) machine tools and radios to Kyrgyzstan, where there
is a high risk of re-exportation to Russia. At the same time, a Kyrgyz bank was made subject to a transac - tion ban in the same package, together with banks in Laos and Azerbaijan, for assisting the Russian war effort through sanctions circumvention or associa - tion with the Russian SPFS payment system. Reuters confirmed in its coverage of 24 April 2026 that “the EU is activating its anti-circumvention tool, by pro - hibiting the export of any computer numerical control machines or radios to Kyrgyzstan”. The relevant legal acts from this package include, among others, Coun - cil Regulation (EU) 2026/506 of 23 April 2026 amend - ing Regulation (EU) No 833/2014. This development continued in the 21st sanctions package of 23 July 2026, in which further entities based in Kyrgyzstan (together with China, India, Kazakhstan, Turkey and the United Arab Emirates) were added to the list of entities contributing to Rus - sia’s circumvention of export restrictions, including in respect of microelectronics, CNC machine tools and semiconductor equipment.
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