Closing the Window of Opportunity: New Restrictions on Transit Payments Through Kyrgyzstan
- What Has Changed?
- Why the Restriction?
- New Requirements for Banks
- Who’s Affected?
- Current Situation
- Bottom Line
- Contact our lawyer for more details
On September 4, 2024, the National Bank of the Kyrgyz Republic adopted a resolution titled “On Ensuring Economic Security and Maintaining Financial Stability.” This resolution introduces significant restrictions that impact international trade and payment flows through Kyrgyzstan.
What Has Changed?
The resolution prohibits banks for one year from processing payment orders or executing contracts related to goods, services, or works not actually delivered to the territory of Kyrgyzstan.
This applies to any transactions without real import into Kyrgyzstan, including goods simply transiting through the country between two foreign states.
Why the Restriction?
The decision was prompted by an increase in cases where Kyrgyzstan was used as a financial intermediary—a convenient transit hub for settlements between foreign parties, without the goods or services being intended for the Kyrgyz market.
New Requirements for Banks
Now, banks are obligated to request cargo customs declarations (GTDs) to verify that goods have crossed into Kyrgyzstan.
No GTD = no payment.
Who’s Affected?
In practice, this means closing any schemes with transit through Kyrgyzstan without importing goods into the country.
Current Situation
As of now, payments for goods transiting through Kyrgyzstan are blocked. This affects:
- Goods shipments, including electronics, consumer products, and auto parts.
- Service contracts using Kyrgyzstan as a payment pass-through.
- Logistics and transport companies managing transit flows.
Bottom Line
Kyrgyzstan is tightening its grip on external financial flows, aiming to combat shadow trading schemes and protect national economic stability.
For businesses, however, this marks a clear shift in trade corridors and necessitates a rethink of international payment strategies.
Contact our lawyer for more details
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