EU Delists Tajik Banks as Kyrgyzstan Feels the Heat

The removal of three Tajik banks from the EU sanctions list highlights diverging compliance trajectories across Central Asia.

By Kulobiddin Norov May 04, 2026 Credit: Depositphotos

On April 23, the European Union removed three Tajik financial institutions – Spitamen Bank, Dushanbe City Bank, and Commercebank of Tajikistan – from its sanctions list as part of its 20th package of restrictive measures targeting Russia. The banks had been sanctioned just five months earlier under the EU’s 19th package, which took effect on November 12, 2025. Under the sanctions, European entities were barred from conducting transactions with the three Tajik banks.

The delisting, announced by the National Bank of Tajikistan, was framed as the result of productive dialogue between Tajik authorities and their European counterparts. According to the regulator, the decision reflects expanded cooperation with the European Commission, the implementation of international compliance standards, and improvements in anti-money laundering mechanisms. During the sanctions period, the affected banks continued operating domestically but faced restrictions on international transfers and correspondent banking relationships.

The EU did not publicly disclose the specific transactions or volumes that originally led to the sanctions. Its 19th package broadly cited the risk that the listed institutions could facilitate the circumvention of restrictions imposed on Russia. In response, Tajikistan’s Foreign Ministry expressed concern and pledged to cooperate with international partners. Tajik authorities subsequently worked to secure the removal by providing guarantees that the banks’ financial operations comply with international standards.

The three Tajik banks were not sanctioned without reason. A July 2025 investigation by the Russian outlet The Bell revealed that Russia’s Sberbank was routing client funds to European bank accounts using Central Asian banks as intermediaries, with transaction records showing Dushanbe as the origin of funds rather than Moscow. Dushanbe City Bank, founded in 2007 under the Avesto Group – a conglomerate closely tied to Tajikistan’s ruling family – was among those mentioned in online ads offering banking services to sanctioned Russian citizens via third-party intermediaries.

The timing of the delisting is notable. While Brussels lifted restrictions on Tajikistan’s banks, the same 20th package imposed transaction bans on two additional Kyrgyz banks – Keremet Bank and Capital Bank of Central Asia – effective May 14, 2026. The EU also activated its anti-circumvention tool against Kyrgyzstan for the first time, banning exports of CNC machines and telecommunications equipment to the country after finding that imports of dual-use goods from Europe to Kyrgyzstan had surged by nearly 800 percent compared to pre-war levels. Kyrgyzstan now has six banks under EU sanctions in total.

The divergence is striking. Tajikistan’s conciliatory approach has allowed it to reverse the EU’s punitive measures in under half a year. Kyrgyzstan, by contrast, has seen its sanctions exposure deepen steadily since 2025. President Sadyr Japarov labeled the earlier sanctions as “one-sided pressure” and visited Moscow the day the 20th package was adopted. Uzbekistan, meanwhile, was notably absent from the EU’s sanctions lists after President Shavkat Mirziyoyev’s diplomatic visit to Brussels and Tashkent’s assurances of strict compliance.

But the Tajik success story deserves scrutiny. The EU’s 20th package stated that the five delisted third-country entities – including two Chinese banks alongside the three Tajik ones – were removed after providing commitments that they would not engage in the activities for which they were listed. Whether Tajikistan’s banking system has undergone meaningful structural reform or simply offered assurances that satisfy Brussels’ procedural requirements is an open question.

The direct channels between Russian and Tajik banking systems, built in the late 2010s to bypass intermediaries like SWIFT, remain intact. The volume of labor remittances from Russia to Tajikistan totalled $5.7 billion in 2023 alone, most of it transferred via those direct channels and therefore invisible to Western monitoring.

For Dushanbe, the delisting is a diplomatic win that restores international banking access at a time when Tajikistan’s economy can ill afford further isolation. For Brussels, the selective application of sanctions and their swift reversal signals that compliance engagement can yield results – but also raises the question of whether the underlying financial architecture that enabled sanctions evasion has actually changed, or whether it has simply learned to avoid the scrutiny.