Export Controls & Dual-Use Goods in Kazakhstan

US Export Administration Regulations (EAR)

The US EAR — administered by the Bureau of Industry and Security (BIS) — controls the export, re-export, and in-country transfer of items subject to the EAR, including those on the Commerce Control List (CCL). EAR jurisdiction extends to items of US origin anywhere in the world, regardless of where the exporting company is located. A Kazakhstan company importing US-origin goods and re-exporting them — directly or indirectly — to a sanctioned destination or an entity on the BIS Entity List without a required licence can breach the EAR. That can expose its US suppliers to enforcement action and the Kazakhstan company itself to denial of US export privileges.

BIS Entity List — Kazakhstan entities

The BIS Entity List identifies specific companies and individuals subject to licence requirements for all items subject to the EAR. The Entity List includes entries with Kazakhstan addresses, three of them added between March 2022 and August 2024 (US Consolidated Screening List, checked 7 November 2026). A Kazakhstan company on the Entity List is effectively cut off from US-origin components, software, and technology — a significant operational constraint for companies in electronics, industrial equipment, and technology sectors. Bond Stone advises on Entity List assessment, licence applications, and compliance remediation.

EU dual-use goods — Regulation 2021/821

EU Regulation 2021/821 controls the export of dual-use items — goods, software, and technology that have both civilian and military applications. The EU has significantly expanded its dual-use controls in the context of Russia sanctions, adding new items and tightening re-export restrictions. A Kazakhstan company importing EU-origin dual-use goods should expect its EU suppliers to carry out due diligence on the final destination and to ask for end-use statements and contractual limits on re-export.

Kazakhstan's export control framework

Kazakhstan maintains its own export control framework — the Law on Control of Specific Goods (No. 172-VII of 28 December 2022), which replaced the 2007 Law on Export Control, and related subordinate legislation. It covers dual-use and military goods and goods controlled for national security; goods on the national control list, drawn up with regard to the lists of the international export control regimes, need a permit for export, re-export, import and transit (Arts. 1, 5, 6, 20). Bond Stone advises on Kazakhstan export licence requirements for controlled goods and compliance with Kazakhstan's domestic export control obligations alongside international requirements.

End-user certificates and due diligence

A key tool in export control compliance is the end-user certificate (EUC) — a document provided by the importing company or its government confirming the intended end use and end user of controlled goods. Western export control authorities increasingly require EUCs from Kazakhstan importers as a condition of export licence approval. Bond Stone advises on preparing and submitting EUC documentation and implementing end-user screening protocols.