Sanctions targeting former post-Soviet countries suspected of acting as conduits for restricted goods to Russia have again placed Central Asia at the centre of Europe’s enforcement debate.
Kyrgyzstan has called for transparent and depoliticised dialogue with the European Commission after the European Union expanded its latest Russia-related sanctions package to include Kyrgyz companies and financial institutions. Bishkek has rejected suggestions that it is assisting sanctions circumvention, saying its companies and banks operate in accordance with domestic legislation and international obligations.
The measures form part of the EU’s 20th sanctions package against Russia, adopted in April. The Council of the EU described the package as a broad set of restrictive measures targeting Russia’s energy revenues, trade, financial services, crypto activity and military-industrial capacity. It also included 120 further listings, the largest package of individual listings in two years.
EU’s 20th sanctions package targets Russia’s energy revenues, banks, crypto and shadow fleet
The package is notable for another reason. For the first time, the EU used its anti-circumvention tool against Kyrgyzstan, restricting the export of certain goods where Brussels says there is a high risk that they could be re-exported to Russia. Reuters reported that the restrictions covered goods including metal-cutting machinery and communications equipment such as modems and routers.
The Kyrgyz case illustrates a wider problem for European sanctions policy. Since Russia’s full-scale invasion of Ukraine in February 2022, the EU, the United States and allied governments have imposed restrictions intended to reduce Moscow’s access to finance, technology, industrial equipment, aviation services and dual-use goods. Yet Russia’s supply chains have not simply disappeared. In many sectors, they have shifted through third countries, brokers, logistics firms, free zones, banks and maintenance providers.
Civil aviation is one of the clearest examples. Russian airlines continue to operate Western-built aircraft, including Airbus and Boeing models, despite restrictions on access to certified parts, maintenance, technical support and aircraft leasing. Keeping those aircraft operational requires a continuing flow of components, repairs and documentation.
Since February 2022, the supply of aircraft parts, technology and related services to Russia has been subject to extensive EU, UK and US sanctions and export controls. EU rules prohibit the sale, supply, transfer or export of aviation and space goods and technology to Russia, or for use in Russia, and also restrict related technical assistance, maintenance and other services. Similar restrictions apply under UK and US regimes. This makes post-invasion aviation supply chains involving Russian operators a matter of regulatory and public-interest concern. Whether any specific transaction amounts to a breach depends on the goods involved, their origin, the parties, the route, the date, and whether any licence, exemption or derogation applied.
The issue is made more acute by the status of some Russian aviation entities appearing in the documents. The UK added JSC Siberia Airlines, also known as S7 Airlines, to its Russia sanctions list in February 2025. The UK statement of reasons says S7 is involved in supporting the Government of Russia by operating in the Russian transport sector, receiving financing directly or indirectly from Russia’s National Wealth Fund, and making available goods or technology that could contribute to the destabilisation of Ukraine. UK financial sanctions include an asset freeze and restrictions on making funds or economic resources available to the designated entity.
The UK designation is separate from the broader aviation restrictions already imposed after Russia’s full-scale invasion of Ukraine. EU sanctions are not limited to dealings with individually listed airlines. They also prohibit the sale, supply, transfer or export of aviation and space goods and technology to Russia, or for use in Russia, and restrict related technical assistance, maintenance and repair services. This means that aviation-parts or maintenance transactions involving Russian operators can raise sanctions concerns even where the specific airline was not individually listed at the time.
Commercial papers, contracts and freight records seen by EU Today show that Russian aviation entities appear in post-February 2022 commercial documentation involving suppliers and maintenance-linked companies in the United Arab Emirates, Jordan and Kyrgyzstan. EU Today does not allege that every transaction referred to in these records was unlawful, unlicensed, non-compliant, or in breach of sanctions. Nor do the documents, by themselves, establish deliberate circumvention, hidden ownership or criminal wrongdoing by any individual or company named. The records are relevant because they show how Russian aviation operators continued to appear in international supply-chain paperwork after Western restrictions were imposed in response to the war.
One group of documents concerns Golden Falcon Aviation FZE, based in Ras Al Khaimah.
A contract dated March 24, 2022 identifies Golden Falcon Aviation FZE as seller and S7 Engineering LLC as buyer. The contract concerns the sale and purchase of aircraft equipment, including tools, test equipment and ground equipment for civil aircraft. It lists S7 Engineering at Domodedovo Airport in the Moscow region and includes legal and banking details for both parties, with signatures and stamps on the final page.
Associated purchase documentation from the same period names Golden Falcon Aviation FZE as supplier to Siberia Airlines JSC. A purchase order dated March 16, 2022 lists aircraft parts including an insert and rivets, gives Golden Falcon’s address as Technology Park, RAK Free Trade Zone, Ras Al Khaimah, and identifies Domodedovo Airport, Moscow, as the shipment destination.
Another document dated March 21, 2022 names Golden Falcon Aviation as supplier to S7 Engineering for an inspected FCU board. S7 Engineering at Domodedovo appears in the paperwork, along with instructions for certificates and invoices to be sent to S7 email addresses. A Golden Falcon Aviation pro forma invoice dated March 23, 2022 is addressed to S7 Technics at Domodedovo Airport and includes bank details for Golden Falcon Aviation FZE at Emirates NBD and the National Bank of Ras Al Khaimah.
The wider material also refers to Casper Aviation Spares Trading FZE, based in the Umm Al Quwain Free Trade Zone. A company data sheet describes its activities as the supply of aircraft spare parts, consumables, expendables, rotables, ground support equipment and repair support.
A further purchase order dated March 3, 2023 names U.C.A Aviation Spares Trading FZE, also based in Umm Al Quwain, as supplier to Siberia Airlines JSC for an inspected and tested Director-CIDS unit valued at $158,000. The shipment destination is listed as Domodedovo Airport, Moscow.
The original source material supplied to EU Today makes broader claims about links between Golden Falcon Aviation, Casper Aviation, UCA and named individuals. Those claims are not presented here as established fact. The documented point is narrower: Russian aviation-linked entities appear in post-invasion commercial paperwork involving UAE-based aviation suppliers and logistics routes.
A separate open-source reference concerns A T S Heavy Equipment and Machinery, a Dubai-based company named in a September 2023 investigation by the Russian outlet IStories, titled “Why Russian Airplanes Keep Flying Despite the Imposed Sanctions”. Citing customs data, IStories reported that the company had made more than 700 deliveries to Russia between March 2022 and March 2023, worth 3.9 billion roubles, and described it as the largest foreign supplier in its sample of aircraft spare-parts vendors.
According to IStories, most of the Boeing and Airbus spare parts supplied through this channel went to the Aeroflot Group, with Russian customers including Aeroflot, Rossiya, Pobeda and S7. The investigation also reported that the beneficiary of A T S Heavy Equipment and Machinery was listed as Jordanian national Mohammad Altahayneh, and noted that his LinkedIn profile connected him to Jordanian Aerospace Technical Services.
In December 2023, three months after the IStories investigation, the US Treasury designated A T S Heavy Equipment and Machinery Spare Parts Trading, stating that the company had delivered millions of dollars’ worth of aircraft parts to Russia.
A third set of material concerns Aeroparts AOG and Royal Aircraft Maintenance Company, known as RAMC.
Dubai licensing material lists Aeroparts AOG DWC-LLC as a company engaged in aircraft spare parts and components trading. The licence names Imad El Eddine Mohamed El Halabi as company manager and gives Aviation District, Dubai, as the area of registration.
Separate material reviewed by EU Today includes commercial aviation documents in which Aeroparts AOG and RAMC appear in connection with Russian aviation-linked counterparties after February 2022. EU Today does not allege that Imad El Eddine Mohamed El Halabi, Aeroparts AOG or RAMC has been found by any court, regulator or sanctions authority to have breached sanctions or engaged in unlawful conduct.
The RAMC material includes an invoice dated January 7, 2025 addressed to S7 Engineering LLC at Domodedovo Airport. It lists aircraft parts described as seals and bushings, with a total stated value of $30,070.
Earlier documents reviewed by EU Today include a RAMC invoice dated September 27, 2022 naming Siberia Airlines JSC and listing aircraft parts including covers, a ring assembly and a pump, with a stated customs value of $70,957.40. An Aeroparts AOG invoice dated August 25, 2022 is addressed to Siberia Airlines JSC, with Moscow Domodedovo Airport listed as the shipping address.
The material also contains freight documentation naming S7 Engineering LLC as consignee and describing the goods as aircraft parts, with routing shown via Dubai World Central, Malé and Sheremetyevo, and Aeroflot Russian Airlines named on the air waybill. That freight document does not itself name RAMC. It appears in the same document set and is linked to the wider Aeroparts/RAMC material through matching purchase-order, part-number and shipment references in accompanying documents. One of those bridge documents, a Greenway Cargo invoice, is disputed by RAMC.
RAMC and Mr El Halabi deny any involvement in sanctions evasion, unlawful conduct, hidden ownership, coordinated networks or assistance to sanctioned persons or entities. They also dispute the authenticity and reliability of several documents in the material reviewed by EU Today, including documents which they say are forged, manipulated, incomplete or misleading. EU Today has reviewed RAMC’s position and notes that the disputed documents and the underlying questions of authenticity would require verification by competent authorities, counterparties, banks, logistics providers or independent forensic experts.
The documents are cited not as proof of a sanctions breach, but because they raise compliance questions about commercial aviation paperwork involving Russian aviation-linked entities after the introduction of Western restrictions on Russia’s aviation sector.
A separate contract dated January 18, 2023 identifies Sky Asia Technics LLC, registered in Bishkek, Kyrgyzstan, as contractor and S7 Engineering LLC as customer. The contract concerns the repair of spare parts, components and aircraft equipment. It does not establish wrongdoing, but it is relevant in the wider context of EU concern over third-country aviation and technical-service routes involving Russian operators.
Taken together, the material shows repeated appearances of Russian aviation-linked entities in commercial documentation involving companies in the UAE, Jordan and Kyrgyzstan after February 2022. It does not establish whether all goods were Western-origin, whether they were subject to EU, UK or US controls, or whether licences were required or obtained. Those questions would require customs records, end-use documentation, payment trails, export-control classifications and formal responses from the companies concerned.
The broader issue is the structure of the aviation supply chain itself. Aircraft parts are specialised, often small, and frequently traded through brokers. A single order can involve an airline, a maintenance provider, a parts supplier, a freight forwarder, a bank, a certifying authority and several jurisdictions. Paperwork may reveal only part of the route.
That complexity is not evidence of wrongdoing. But it can create compliance questions where Russian end-users are involved, particularly in sectors subject to export controls or sanctions screening. It also increases the burden on manufacturers, banks, insurers, freight companies, customs authorities and aviation regulators to establish the final destination and end-use of goods and services.
The Kyrgyzstan sanctions place this issue in a broader EU policy context. Brussels is no longer focused only on Russian banks, state companies, oligarchs and military-industrial entities. It is increasingly targeting third-country channels where it believes restricted goods may be diverted to Russia. The European Commission says the anti-circumvention tool allows the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to third countries where there is a high risk of diversion to Russia.
Although much of the aviation material concerns UAE and Jordan-based companies, rather than Kyrgyzstan alone, it raises the same enforcement question: how effective are sanctions if Russian end-users continue to appear in commercial records involving suppliers outside Russia?
The available documents do not prove a co-ordinated network. They do not prove intent, hidden ownership, insider assistance or sanctions breaches by all named companies. Such matters would require corporate registry records, customs declarations, payment confirmations, sanctions-screening material, supplier correspondence and formal comment from the parties involved.
They do, however, provide grounds for further examination by competent authorities and compliance departments. Russian aviation entities appear in post-invasion supply-chain documentation outside Russia. In the context of EU sanctions policy, that is relevant.
Kyrgyzstan may be the current focus of Brussels’ anti-circumvention measures, but the wider challenge extends beyond Central Asia. Russia’s access to international markets has been formally restricted, yet the commercial routes connecting brokers, free zones, banks, freight handlers and maintenance providers remain difficult to monitor.
If Russian airlines continue to obtain parts and repair services through third countries, the issue is not merely technical. It goes to the effectiveness of the sanctions imposed after Russia’s invasion of Ukraine, and to the ability of European and allied authorities to enforce those measures across the global supply chains on which Russia still depends.
