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.
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.
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.
Now, banks are obligated to request cargo customs declarations (GTDs) to verify that goods have crossed into Kyrgyzstan.
No GTD = no payment.
In practice, this means closing any schemes with transit through Kyrgyzstan without importing goods into the country.
As of now, payments for goods transiting through Kyrgyzstan are blocked. This affects:
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.
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