OSCEs Parlamentariske Forsamling 2022-23 (2. samling)
OSCE Alm.del Bilag 11
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 OSCE, Alm.del - 2022-23 (2. samling) - Bilag 11: Reports on Kazakhstan Helping Russia Circumvent Western Sanctions - Open Dialogue Foundation
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The Open Dialogue Foundation
was established in Poland in 2009 on the initiative of Ukrainian student and civic activist
Lyudmyla Kozlovska (who currently serves as President of the Foundation). Since its founding, statutory objectives of the
Foundation include the protection of human rights, democracy and the rule of law in the post-Soviet area. In July 2017 area of
interest of the Foundation was expanded due to the rapidly deteriorating situation in Poland and other EU member states
affected by illiberal policies implemented by their populist governments. The Foundation has its permanent representations in
Brussels, Warsaw and Kyiv.
Website:
https://odfoundation.eu/
; e-mail:
[email protected]
Twitter:
@ODFoundation
Project Manager:
Lyudmyla Kozlovska (the Open Dialogue Foundation): [email protected]
Copyright:
The Open Dialogue Foundation, December 2022
The Open Dialogue Foundation
is grateful to Mukhtar Ablyazov, an opposition politician and former Minister of Energy, Industry
and Trade of Kazakhstan (1998-1999),
for his advice in writing this report.
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 OSCE, Alm.del - 2022-23 (2. samling) - Bilag 11: Reports on Kazakhstan Helping Russia Circumvent Western Sanctions - Open Dialogue Foundation
Table of Contents:
1. INTRODUCTION .......................................................................................................................................... 4
2. HOW KAZAKHSTAN IS HELPING RUSSIA CIRCUMVENT THE OIL EMBARGO .............................................. 7
3. KAZAKHSTAN OIL MARKET ......................................................................................................................... 7
4. EXPORTS OF RUSSIAN OIL AND OIL PRODUCTS TO THE EU ....................................................................... 8
5. A SCHEME TO CIRCUMVENT THE OIL EMBARGO ...................................................................................... 9
Substitution of Russian petroleum products and increased crude oil exports to the EU ........................ 9
Helping Russia sell its oil............................................................................................................................ 9
Total compensation for Russia's supply losses in the crude oil and petroleum products market ......... 10
The myth of diversification of oil supply routes from Kazakhstan ......................................................... 11
6. CONTEXT OF THE SITUATION ................................................................................................................... 12
7. CONCLUSION AND RECOMMENDATIONS................................................................................................ 15
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1. INTRODUCTION
Since Russia's invasion of Ukraine on 24 February 2022, the Kazakhstani authorities has repeatedly
declared its "respect for Ukraine's sovereignty and territorial integrity".
1, 2, 3
Kazakhstani officials try to
assure Ukraine and the international community that Kazakhstan is "complying with the sanctions"
against Russia, although it is not "joining them".
4
In practice, the statements by the Kazakhstani
authorities are an attempt to avoid secondary and personal sanctions for helping the Kremlin circumvent
international sanctions and finance the war against Ukraine.
5
The Kazakhstani authorities conduct disinformation operations against Ukraine and the West, positioning
itself as "a victim of potential Russian aggression" in order to avoid responsibility for helping Russia.
On 5 December 2022, the European Union imposed an embargo on Russian crude oil and from 5 February
2023 an embargo on Russian refined petroleum products will come into effect.
6
The oil embargo has also
been imposed by the US and Canada, while the UK will impose a ban on Russian crude oil imports from
31 December 2022.
7, 8, 9
The European Union, G7 countries and Australia have imposed a price cap on
Russian crude oil of USD 60 per barrel.
10
The purpose of these measures is for Western countries to
cut
energy export revenues
and thus reduce the Kremlin's financial resources to continue its war against
Ukraine.
11
EU governments are looking for alternative sources to replace Russian petroleum products, including
Kazakhstan. On 21 December 2022, for example, it was reported that Kazakhstan "intends to send its first
shipment of oil to Germany in January 2023."
12
For this, Kazakhstan plans to obtain "permission from the
Russian trunk pipeline operator Transneft, since the supplies will go through Russian territory."
Kazakhstan is coordinating this issue with Transneft.
13
In this report we present evidence as to why using
Kazakhstan as an alternative source of oil and petroleum products to the EU above Kazakhstan's existing
annual supply volumes would undermine the political objective of depriving Russia of the means to
conduct military aggression against Ukraine.
When choosing a source of replacement for Russian crude oil and petroleum products, it should be taken
into account that as of 30 December 2022 there is
a legitimate scheme to circumvent the oil embargo,
allowing Kazakhstan to partially (20% of total Russian crude oil and petroleum product exports to the
EU) compensate for Russian losses in oil and petroleum product export volumes.
1
2
https://tengrinews.kz/kazakhstan_news/pochemu-kazahstan-progolosoval-protiv-rezolyutsii-kryimu-487228/
https://rus.azattyq.org/a/31786625.html
3
https://www.euractiv.com/section/central-asia/interview/kazakh-official-we-will-not-risk-being-placed-in-the-same-basket-as-russia/
4
https://www.vedomosti.ru/politics/news/2022/12/26/957011-glava-mid-kazahstana-poobeschal-ne-pomogat-rossii
5
https://en.odfoundation.eu/a/494919,kremlins-secret-ally-how-tokayev-is-helping-putin-circumvent-sanctions/
6
https://www.consilium.europa.eu/en/policies/sanctions/restrictive-measures-against-russia-over-ukraine/sanctions-against-russia-explained/
7
https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/08/fact-sheet-united-states-bans-imports-of-russian-oil-liquefied-natural-gas-
and-coal/
8
https://www.cbc.ca/news/politics/foreign-affairs-minister-more-lethal-aid-shipments-for-ukraine-1.6367163
9
https://sanctionsnews.bakermckenzie.com/uk-introduces-further-sanctions-against-russia-4/
10
https://www.reuters.com/business/energy/holdout-poland-approves-eus-60-russian-oil-price-cap-with-adjustment-mechanism-2022-12-02/
11
https://www.eeas.europa.eu/delegations/ukraine/questions-and-answers-g7-agrees-oil-price-cap-reduce-russias-revenues-while_en
12
https://rus.azattyq.org/a/32198182.html
13
https://informburo.kz/novosti/glava-kmg-probnuyu-partiyu-kazaxstanskoi-nefti-mogut-otpravit-v-germaniyu-uze-v-yanvare
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Kazakhstan can compensate for Russia's losses in the following way:
•
Of the 108 million tonnes of oil previously supplied by Russia to Europe, Kazakhstan is helping
Russia sell at least 27 million tonnes of oil (25% of Russia's total oil exports to the EU) under this
scheme:
a. 12 million tonnes of Russian oil Kazakhstan will purchase for its refineries, and its own oil
of 12 million tonnes, previously used for its refineries to produce petroleum products,
Kazakhstan will export to the EU.
b. 10 million tonnes of additional Russian oil will pass through the Atasu-Alashankou pipeline
from Kazakhstan to China, which has a capacity of 20 million tonnes.
c. 5 million tonnes of Russian oil will be sold to Uzbekistan by pipeline through Kazakhstan.
•
Of the 91 million tonnes of petroleum products previously supplied by Russia to Europe,
Kazakhstan will buy more than 13 million oil products from Russia (just over 14% of total Russian
oil product exports to the EU) for its domestic market.
Through this scheme to circumvent the embargo, Kazakhstan will compensate Russia for 20% of Russia's
crude oil and petroleum product export losses to the EU. This
will keep Russian budget revenues from
the sale of oil and petroleum products at a high level.
Kazakhstan is also helping Russia to redirect Russian
crude oil exports to the Chinese market using the Atasu-Alashankou pipeline. The scheme to circumvent
Russia's oil embargo through Kazakhstan
requires a detailed study and prompt reaction from the
democratic governments of Ukraine, the EU, the US, Canada and the UK.
In addition to Kazakhstan's existing schemes to help finance the war and circumvent international
sanctions, including the supply of goods used for military purposes,
14
the Kazakh authorities' assistance
to the Kremlin to circumvent the oil embargo
deliberately undermines international efforts
to reduce
Russia's financial, military and technological resources to continue the war, protect Ukraine's
independence, sovereignty and territorial integrity and ensure a just peace in the foreseeable future.
Recommendations:
•
Immediately shut down Russia's ability to circumvent the oil embargo, international sanctions
through Kazakhstan and other Central Asian countries to deprive Russia of its ability to finance a
war against Ukraine;
Impose personal sanctions on individuals and entities, including government officials, who
contribute to circumventing the sanctions and the oil embargo;
Implement the recommendations given in the European Parliament resolution dated 20 January
2022,
15
especially the requirement for Kazakhstan to allow the UN and the OSCE experts to conduct
an international investigation into the role of the CSTO military contingent in suppressing peaceful
mass protests in Kazakhstan in January 2022;
•
•
14
15
https://en.odfoundation.eu/a/494919,kremlins-secret-ally-how-tokayev-is-helping-putin-circumvent-sanctions/
https://www.europarl.europa.eu/doceo/document/TA-9-2022-0012_EN.html
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•
Provide political and financial support to an independent civil society and opposition in Kazakhstan
that exposes Tokayev's assistance in circumventing international sanctions for the Kremlin and
surrendering Kazakhstan's national interests to Russia.
Curb the misuse of inter-state criminal and civil law cooperation instruments, as well as cases of
illegal surveillance on EU territory of the opposition and their loved ones; investigate and suppress
information attacks aimed at misleading EU authorities and obtain the extradition of opposition
representatives from EU countries to Kazakhstan who systematically expose Tokayev's assistance
in circumventing international sanctions for the Kremlin and surrendering Kazakhstan's national
interests in favour of Russia.
•
This report is the second in a series entitled "Kremlin’s
Secret Ally. HOW TOKAYEV IS HELPING PUTIN
CIRCUMVENT SANCTIONS" and provides information on the schemes Tokayev uses to help Putin
circumvent the oil embargo.
16
The report has been prepared by the human rights Open Dialogue Foundation on the basis of public
sources, expert reviews of Kazakhstani citizens who disagree with President Tokayev's pro-Kremlin
policies. We are grateful to opposition politician Mukhtar Ablyazov, former Minister of Energy, Industry
and Trade of the Republic of Kazakhstan (1998-1999), for his advice in writing this report.
16
https://en.odfoundation.eu/a/494919,kremlins-secret-ally-how-tokayev-is-helping-putin-circumvent-sanctions/
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2. HOW KAZAKHSTAN IS HELPING RUSSIA CIRCUMVENT THE OIL EMBARGO
Russia's invasion of Ukraine and Western countries' refusal to import Russian crude oil and petroleum
products has forced the governments of EU member states to look for alternative sources to replace
Russian oil and petroleum products, considering, among others, Kazakhstan.
On 21 December 2022, for example, it became known that Kazakhstan "intends to send its first shipment
of oil to Germany in January 2023."
17
It is supposed to go through the Atyrau-Samara pipeline and then
through the Druzhba pipeline to Europe. For this purpose Kazakhstan plans to obtain "permission from
the Russian trunk pipeline operator Transneft, since the supply will go through Russian territory."
Kazakhstan is coordinating this issue with Transneft.
18
Thanks to the pro-Kremlin stance and actions of
Kazakhstan's leadership, Kazakhstan is helping Russia to partially compensate for the loss of European
crude oil and petroleum product exports. Using Kazakhstan as an alternative source of oil and petroleum
product supply to the EU above Kazakhstan's existing annual export volumes would undermine the
political objective of depriving Russia of the means to conduct military aggression against Ukraine.
3. KAZAKHSTAN OIL MARKET
According to the data from the Ministry of Energy of Kazakhstan for 2021, oil production in Kazakhstan
amounted to
85.7 million tonnes.
19
Kazakhstan's total crude oil exports amounted to
67.6 million tonnes.
The remaining
17.1 million tonnes
are refined by Kazakhstani refineries.
Of Kazakhstan's total oil exports (67.6 million tonnes), over 90% of crude oil exports go through Russia:
•
•
53 million tonnes through the Caspian Pipeline Consortium (CPC)
12 million tonnes through the Atyrau-Samara oil pipeline.
20
2 million tonnes are exported through the port of Aktau to Azerbaijan and onwards through the Baku-
Tbilisi-Ceyhan pipeline and 1 million tonnes to China through the Atasu-Alashankou pipeline.
21, 22
17
18
https://rus.azattyq.org/a/32198182.html
https://informburo.kz/novosti/glava-kmg-probnuyu-partiyu-kazaxstanskoi-nefti-mogut-otpravit-v-germaniyu-uze-v-yanvare
19
https://kz.kursiv.media/2021-12-28/obem-dobychi-nefti-po-itogam-2021-goda-v-kazakhstane-sostavil-857-mln/
20
https://lsm.kz/kakie-al-ternativnye-marshruty-eksporta-nefti-est-u-kazahstana
21
https://www.ankasam.org/%D1%8D%D0%BD%D0%B5%D1%80%D0%B3%D0%B5%D1%82%D0%B8%D1%87%D0%B5%D1%81%D0%BA%D0%B8%D0%B5-
%D0%BC%D0%B0%D1%80%D1%88%D1%80%D1%83%D1%82%D1%8B-
%D0%BA%D0%B0%D0%B7%D0%B0%D1%85%D1%81%D1%82%D0%B0%D0%BD%D0%B0/?lang=ru
22
https://lsm.kz/kakie-al-ternativnye-marshruty-eksporta-nefti-est-u-kazahstana
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Kazakhstan oil export routes in 2021
Kazakhstan's adjusted crude oil production forecast for 2022 is
84 million tonnes.
23
Refining volume is
predicted to be
18 million tonnes.
24
The oil production forecast for 2023 is
90.3 million tonnes.
25
Key importers of Kazakhstani oil are the European Union (70% of total oil exports), China (3.6 million
tonnes) and South Korea (3.3 million tonnes).
26, 27
4. EXPORTS OF RUSSIAN OIL AND OIL PRODUCTS TO THE EU
On 5 December 2022, the EU imposed an embargo on Russian crude oil and from 5 February 2023 there
will be a ban on imports of Russian petroleum products.
28
In 2021 Russia exported
229.9 million tonnes
of oil, of which the EU
had 47%
or
108.1 million tonnes.
29
In 2021, Russia produced
270 million tonnes of petroleum products,
of which
91 million tonnes
were
exported to the EU.
30
23
24
https://rus.azattyq.org/a/32200237.html
https://tengrinews.kz/kazakhstan_news/skolko-nefti-planiruet-dobyit-kazahstan-v-2023-godu-487414/
25
https://rus.azattyq.org/a/32200237.html
26
https://www.eeas.europa.eu/kazakhstan/european-union-and-kazakhstan_en?s=222
27
https://lsm.kz/eksport-kazahstanskoj-nefti-v-2021-godu-infografika
28
https://www.gazeta.ru/business/2022/12/05/15890353.shtml
29
https://tass.ru/ekonomika/16498787
30
https://www.vedomosti.ru/business/articles/2022/11/09/949432-neftyaniki-pereorientirovali-dizel-na-vnutrennii-rinok
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5. A SCHEME TO CIRCUMVENT THE OIL EMBARGO
Substitution of Russian petroleum products and increased crude oil exports to the EU
The political aim of the EU, the USA, the UK and Canadian oil embargoes and the imposition of a price cap
on Russian oil is the desire of Western countries to cut energy export revenues and, consequently, the
Kremlin's financial resources to continue its war against Ukraine.
31
However,
there is a legitimate scheme
to circumvent the oil embargo, allowing Kazakhstan to partially (20% of Russia's total oil and petroleum
product exports to the EU) compensate Russia for its loss in oil and petroleum product export volumes.
Kazakhstan refines about
17.1 million tonnes
of oil at the three largest refineries (Shymkent, Pavlodar
and Atyrau) and other mini-refineries.
32
Production of petroleum products is about
13.1 million tonnes
of petroleum products sold in Kazakhstan's domestic market.
To compensate for its losses from the embargo, Russia will sell to Kazakhstan
12 million tonnes
of oil for
processing at Kazakhstan's Pavlodar and Shymkent refineries. Oil products produced at these refineries
from Russian crude oil, as well as oil products produced at the Atyrau Refinery from Kazakh oil, in the total
amount of over 13 million tonnes will be sold to the EU as Kazakhstani exports legally.
13 million tonnes of petroleum products is about
14%
of total petroleum product exports from Russia to
the EU for 2021. At the same time, Kazakhstan will buy an additional 13 million tonnes of petroleum
products from Russia for delivery to the Kazakhstani domestic market.
Thanks to this, Kazakhstan can legally supply an additional 13 million tonnes of petroleum products to the
European market
(instead of selling them for domestic consumption in Kazakhstan).
Thus, Kazakhstan could export to the EU in 2023:
•
79.6 mtpa oil
instead of the previously supplied 67.6 mtpa (an increase of
12 mtpa oil
due to
Russian oil to be imported through pipeline systems from Russia to Pavlodar and Shymkent
refineries. Kazakhstan, instead of loading these refineries with its own oil, will export it to the EU).
13 million tonnes of petroleum products
from oil purchased in Russia and refined at the Shymkent
and Pavlodar refineries, as well as petroleum products produced at the Atyrau refinery from
Kazakhstani oil.
•
Helping Russia sell its oil
Kazakhstan can also help Russia sell an additional
10 million tonnes
of oil to China through the China-
Kazakhstan Atasu-Alashankou pipeline from Kazakhstan to China. The Atasu-Alashankou oil pipeline has
a capacity of 20 million tonnes.
33
Russia already supplies 10 million tonnes of oil to China through this
31
32
https://www.cnn.com/2022/12/05/energy/russia-oil-embargo-price-cap-explainer/index.html
https://kz.kursiv.media/2021-12-28/obem-dobychi-nefti-po-itogam-2021-goda-v-kazakhstane-sostavil-857-mln/
33
https://www.vedomosti.ru/business/articles/2022/07/07/930415-kazahstan-postavki-nefti
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pipeline. As of 30 December 2022,
Russia is able to sell 20 million tonnes of oil to China
through the
Atasu-Alashankou pipeline
with the help of Kazakhstan
without any problems.
The map of Kazakhstan main pipelines
34
There is also a project underway to supply oil through the Omsk (Russia)-Pavlodar (Kazakhstan)-Shymkent
(Kazakhstan)-Uzbekistan oil pipeline. In the long term, another 5 million tonnes of Russian oil could be
supplied to Uzbekistan's refinery via this route.
35
Including the 12 million tonnes of Russian oil that Kazakhstan buys from Russia for refining at its refineries,
Kazakhstan is helping Russia sell at least
27 million tonnes of oil, or 25%
of the 108 million tonnes of oil
that Russia previously supplied to Europe.
Total compensation for Russia's supply losses in the crude oil and petroleum products market
In total, of the 199 million tonnes of oil and petroleum products supplied by Russia to Europe in 2021,
Kazakhstan can help Russia to compensate for the loss of exports of 40 million tonnes of crude oil and
petroleum products (or 20% of the total loss of exports).
For Kazakhstan, whose 2021 Gross Domestic Product (GDP) is nine times less than Russia's,
the ability to
compensate for 20% of Russia's crude oil and petroleum product export losses is significant.
34
35
https://stanradar.com/news/full/32511-tranzitnyj-separatizm-na-neftegazovom-prostranstve-eaessng-dominiruet.html
https://tj.sputniknews.ru/20170503/uzbekistan-dlya-stroyashchegosya-novogo-NPZ-protyanet-nefteprovod-kazakhstan-1022213072.html
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It is important to note that the aforementioned methods of selling Russian oil and petroleum products
do
not violate the sanctions regime.
However,
they directly contradict the political objective of the West
to reduce Russian budget revenues through the sale of oil and petroleum products.
In addition to reorienting Russian crude oil exports towards Asian markets, Kazakhstan's assistance in
closing 20% of Russia's oil and petroleum product export losses
allows Russian budget revenues from oil
and petroleum product sales to be kept high.
The myth of diversification of oil supply routes from Kazakhstan
In July 2022, during a phone call between President Tokayev and European Council President Charles
Michel, Tokayev said that Kazakhstan was "ready
to use its hydrocarbon potential to stabilise world and
European markets."
36
Tokayev also ordered to diversify Kazakhstan's oil supplies to foreign markets,
allegedly to reduce the country's logistical dependence on Russia.
37
In fact, Kazakhstan is misleading the
world community. The truth is that Kazakhstan has no alternative oil export routes other than through
Russian territory.
38
An alternative route through the port of Aktau and onwards through Azerbaijan (the
so-called Trans-Caspian route), Georgia and Turkey, allows exporting a maximum of 5 million tonnes of
Kazakhstani oil in the long term.
39
At the same time, 65 million tons of oil from Kazakhstan are exported
through the territory of Russia. Therefore, the bulk of Kazakhstan's oil supplies to the EU can only go
through Russian territory.
Germany plans to buy oil from Kazakhstan through the Druzhba pipeline (through the Atyrau-Samara
pipeline and onwards through Belarus, Poland and Germany).
40, 41
However, Kazakhstan cannot
significantly increase the existing annual export volumes of oil and petroleum products to Europe, as the
country cannot significantly increase oil production in the short term. Kazakhstan can only increase its
exports of oil and petroleum products to Europe by supplying Europe with the volumes of oil and
petroleum products that are used in the domestic market of Kazakhstan. At the same time, Kazakhstan
compensates the needs of the domestic market by importing oil and oil products from Russia.
In this way, the Kazakhstani authorities create the illusion that they are helping the EU overcome the
energy crisis without Russia. However, in reality, Kazakhstan will help Russia compensate for its losses
from the oil embargo.
By acting as the "saviour" of the European Union, the Kazakhstani authorities will be able to:
•
•
avoid sanctions for helping Russia circumvent international sanctions
avoid Western criticism for systematic and serious human rights violations in the country.
36
37
https://www.akorda.kz/ru/telefonnyy-razgovor-s-prezidentom-evropeyskogo-soveta-sharlem-mishelem-465120
https://kapital.kz/economic/107046/prezident-poruchil-diversifitsirovat-postavki-nefti.html
38
https://www.vedomosti.ru/business/articles/2022/08/12/935817-smozhet-li-kazahstan-naladit-postavki
39
https://rus.azattyk.org/a/31985519.html
40
https://www.kommersant.ru/doc/5735000
41
https://rus.azattyq.org/a/32198182.html
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Using Kazakhstan as an alternative source of oil and oil products in the European Union above
Kazakhstan's existing annual supply volumes would undermine the political objective of the West to
deprive Russia of the means to wage military aggression against Ukraine.
The route map of the Druzhba oil pipeline
42
6. CONTEXT OF THE SITUATION
Since the beginning of Russia's full-scale military invasion of Ukraine in February 2022, Kazakhstan's
leadership has taken various measures to convince Western countries and Ukraine to "respect Ukraine's
sovereignty and territorial integrity" and "comply with sanctions". The Kazakhstani authorities make
statements in the international media about "respecting Ukraine's territorial integrity" and "complying
with the sanctions".
43, 44
In March 2022, the Kazakhstani authorities formed a "guidebook of prohibited
goods" (sanctioned goods banned for export to Russia and Belarus).
45
In August 2022, the government of
Kazakhstan issued a decree banning the export of military goods.
46
In December 2022, President Tokayev
signed a law on special export controls for "specific goods" (goods used for military purposes).
47
In this
way, the Kazakhstani authorities are trying to assure Ukraine and Western countries that appropriate
measures are being taken to "comply with sanctions" against Russia.
42
43
https://iz.ru/1409253/mariia-shaipova/druzhba-vroz-chto-izvestno-glavnom-nefteprovode-iz-rossii-v-evropu
https://www.euractiv.com/section/central-asia/interview/kazakh-official-we-will-not-risk-being-placed-in-the-same-basket-as-russia/
44
https://www3.nhk.or.jp/news/html/20221225/k10013933921000.html
45
https://www.inform.kz/ru/putevoditel-zapreschennyh-dlya-eksporta-i-importa-v-rf-i-rb-tovarov-sozdali-v-kazahstane_a3916661
46
https://primeminister.kz/ru/news/kazahstan-na-god-priostanovit-eksport-voennoy-produkcii-2775032
47
https://tengrinews.kz/kazakhstan_news/tokaev-podpisal-zakon-o-kontrole-spetsificheskih-tovarov-487227/
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However, the facts indicate that the declared position and the aforementioned actions of Kazakhstan's
leadership are aimed at misleading Ukraine and Western countries. In a report published by international
and Kazakhstani human rights activists, evidence has been gathered of how Tokayev provides full support
to the Kremlin in financing the war and circumventing international sanctions, including the supply of
components for missiles with which Russia is deliberately destroying Ukrainian civilian infrastructure.
48
In order to avoid secondary and personal sanctions for helping Russia, the Kazakhstani authorities are
conducting large-scale disinformation operations against Ukraine and the West, forming the image of a
"victim of potential aggression by Russia", thus trying to convince Ukraine and the West that Kazakhstan
is allegedly trying to distance itself from the Kremlin and could become the "next victim of aggression".
The same disinformation rhetoric is also used by Kazakhstani diplomats, as well as representatives of
state-sponsored Kazakhstani "think tanks".
Kazakhstan's leadership has abused Western trust to "reduce the impact of anti-Russian sanctions on
Kazakhstan's economy", while the United States and the European Union assure Kazakhstan that they are
taking measures to mitigate the impact of anti-Russian sanctions on Kazakhstan's economy.
49, 50, 51, 52
In
this way, the Kazakhstani authorities manage to mislead Western countries and use various schemes to
help circumvent international sanctions and supply Russia with necessary sanctioned goods. Kazakhstan’s
leadership, through its state agencies in Kazakhstan, including the Ministry of Foreign Affairs, the National
Bank of Kazakhstan, the Agency for Regulation and Development of the Financial Market and National
Management Holding Baiterek, has lobbied the West to ease or lift sanctions imposed on financial
institutions (Sberbank Kazakhstan, Alfa-Bank Kazakhstan) and payment systems (Mir).
The practical support of Kazakhstan's leadership for Russia is evidenced not only in helping it circumvent
international sanctions, but also in supporting Russia's position in the international arena, as you can read
in detail in our previous report.
53
The Kazakhstani authorities have purposefully and consistently supported integration alliances with the
Kremlin, such as the Eurasian Economic Union (EEU) and the Collective Security Treaty Organisation
(CSTO). The Kazakhstani leadership's voluntary surrender of independence and sovereignty in favour of
Russia began before Russia's invasion of Ukraine in February 2022.
54, 55
Consistent support for the Kremlin
and its propaganda rhetoric is also demonstrated on a historical and ideological level. During his visit to
Moscow on 28 November 2022, Tokayev signed a joint declaration with Putin stating that Kazakhstan and
Russia "will not accept any attempts to falsify shared history" - essentially repeating the Kremlin's rhetoric
on Ukraine and the West.
56, 57, 58
48
49
https://en.odfoundation.eu/a/494919,kremlins-secret-ally-how-tokayev-is-helping-putin-circumvent-sanctions/
https://tengrinews.kz/kazakhstan_news/posolstve-ssha-vyiskazalis-vliyanii-sanktsiy-kazahstan-463535/
50
https://www.gazeta.ru/politics/2022/11/17/15796027.shtml
51
https://tengrinews.kz/kazakhstan_news/posolstve-ssha-vyiskazalis-vliyanii-sanktsiy-kazahstan-463535/
52
https://www.gazeta.ru/politics/2022/11/17/15796027.shtml
53
https://en.odfoundation.eu/a/494919,kremlins-secret-ally-how-tokayev-is-helping-putin-circumvent-sanctions/
54
https://en.odfoundation.eu/a/109524,kazakhstan-surrender-of-technological-sovereignty-to-russia-china-and-a-further-assault-on-civil-society-and-
liberties/
55
https://en.odfoundation.eu/a/178807,kazakhstan-unprecedented-acts-of-the-regimes-terror-against-civilians-and-the-russian-led-cstos-military-
intervention/
56
https://www.vedomosti.ru/politics/news/2022/08/15/936056-putin-zayavil-o-neobhodimosti-zhestko-reagirovat-na-popitki-falsifikatsii-istorii
57
https://iz.ru/1425849/2022-11-15/putin-nazval-tcel-popytok-falsifikatcii-istorii-zapadnymi-stranami
58
https://iz.ru/1432493/2022-11-28/putin-i-tokaev-podpisali-sovmestnuiu-deklaratciiu-po-itogam-vstrechi-v-kremle
13
 OSCE, Alm.del - 2022-23 (2. samling) - Bilag 11: Reports on Kazakhstan Helping Russia Circumvent Western Sanctions - Open Dialogue Foundation
2660750_0014.png
Marked quote: “The
document stresses that the countries will continue to take close positions on
topical international issues and will not accept any attempts to falsify common history.”
The political support of Kazakhstan’s leadership for Russia and the
CSTO is also confirmed by the fact that
on the day of a massive missile strike on Ukraine, 23 November 2022, Imangali Tasmagambetov became
head of the Collective Security Treaty Organisation (CSTO). Tasmagambetov is one of Kazakhstan’s most
influential officials, close to former President Nursultan Nazarbayev. Tasmagambetov is a former prime
minister of Kazakhstan, former mayor of Astana, former defence minister and former ambassador of the
Republic of Kazakhstan to Moscow.
59, 60
Tasmagambetov's appointment as secretary-general of the
organisation, which is effectively run by Russia, comes against the backdrop of the European Parliament's
recognition of Russia as a state sponsor of terrorism.
61
On 30 December 2022, it was reported that Kazakhstan extradited to Russia Mikhail Zhilin, a member of
the Federal Protective Service, who fled to Kazakhstan in September to avoid being sent to fight in
Ukraine. Mikhail Zhilin's wife said the Kazakhstani authorities extradited him to Russia "although the
refugee review procedure has not been completed". This once again indicates that the Kazakhstani
authorities support the Kremlin in its war against Ukraine, as Mikhail Zhilin fled to Kazakhstan and sought
political asylum, not wanting to go to war in Ukraine.
62
Tokayev also supported Putin's idea of a "triple union" of Russia, Kazakhstan and Uzbekistan, which is
clearly Putin's plan to create a union state along the lines of Russia and Belarus, where key strategic
decisions are taken in the Kremlin.
63
Russia's takeover of Kazakhstan and Uzbekistan will strengthen
Putin's political, economic and military capacity to continue his war against Ukraine.
Back in January 2022, Tokayev said Russia was a "union state" for Kazakhstan, and in October 2019, in
Sochi, Tokayev said Russia "should play a leading role" in Central Asia:
“Central
Asia is becoming an
59
60
https://www.pravda.com.ua/rus/news/2022/11/23/7377667/
https://informburo.kz/novosti/imangali-tasmagambetov-stal-generalnym-sekretaryom-odkb
61
https://www.bbc.com/russian/news-63723565
62
https://rus.azattyq.org/a/32200307.html
63
https://iz.ru/1425849/2022-11-15/putin-nazval-tcel-popytok-falsifikatcii-istorii-zapadnymi-stranami
14
 OSCE, Alm.del - 2022-23 (2. samling) - Bilag 11: Reports on Kazakhstan Helping Russia Circumvent Western Sanctions - Open Dialogue Foundation
2660750_0015.png
important factor, a player in pan-Asian cooperation and security. You know very well that it is this region
that the interests of the world's leading states are riveted to. And here Russia, in my opinion, should play
a leading role, because historically Central Asia was part of the Russian Empire. It is quite natural for the
Russian Federation to have a long-term presence - be it political or economic -
in this region.”
64,
65
Thus, Kazakhstan is politically controlled by Russia, as is Belarus, but Kazakhstan's role is to be the
Kremlin's "economic rear" in the war against Ukraine. To this end, the image of "balancing" Tokayev and
Kazakhstan as "victims of potential aggression from Russia" is created, as the imposition of sanctions
against individuals and companies from Kazakhstan will lead to a shutdown of sanctions circumvention
schemes and a weakening of Russia.
7. CONCLUSION AND RECOMMENDATIONS
As long as Russia's direct allies, like Kazakhstan, are able to help Russia circumvent sanctions and generate
high export revenues, Russia will not suffer the economic losses that are expected as a result of Western
sanctions.
Recommendations:
•
Immediately shut down Russia's ability to circumvent the oil embargo, international sanctions
through Kazakhstan and other Central Asian countries to deprive Russia of its ability to finance a
war against Ukraine.
Impose personal sanctions on individuals and entities, including government officials, who
contribute to circumventing the sanctions and the oil embargo.
Implement the recommendations given in the European Parliament resolution dated 20 January
2022,
66
especially the requirement for Kazakhstan to allow the UN and the OSCE experts to conduct
an international investigation into the role of the CSTO military contingent in suppressing peaceful
mass protests in Kazakhstan in January 2022.
Provide political and financial support to an independent civil society and opposition in Kazakhstan
that exposes Tokayev's assistance in circumventing international sanctions for the Kremlin and
surrendering Kazakhstan's national interests to Russia.
Curb the misuse of inter-state criminal and civil law cooperation instruments, as well as cases of
illegal surveillance on EU territory of the opposition and their loved ones; investigate and suppress
information attacks aimed at misleading EU authorities and obtain the extradition of opposition
representatives from EU countries to Kazakhstan who systematically expose Tokayev's assistance
in circumventing international sanctions for the Kremlin and surrendering Kazakhstan's national
interests in favour of Russia.
•
•
•
•
64
https://www.facebook.com/mukhtar.ablyazov/posts/pfbid0g79eUeNWnyaJLCMDLHuWUQ8stNAQz2gHs75ESJauayRufmVT2x1EYEwXM8LyGaRDl?__cft__[
0]=AZV8lgjB0SSDaOcBR7oqVnrxhNU6CNi5OoLIZ1LtFdGtsyXwVsdjoi4r1n2en6ToiQg514u4PFzAvP_3Myh8YIgYnHxDTuyImsXNfbESp7VIORUpG4O2ImqZjc-
jaMQpiBBqm0OFsDVbxQC-lcixUJr4&__tn__=%2CO%2CP-R
65
https://rus.azattyq.org/a/30199013.html
66
https://www.europarl.europa.eu/doceo/document/TA-9-2022-0012_EN.html
15