A Waiver Two Days Before Samarkand
Marco Rubio landed in Samarkand on Sunday for his first trip to Central Asia as secretary of state, with more than 100 American companies in tow. He is there to talk about critical minerals, trade corridors and finance. Two days earlier, President Trump had waived the provisions of a new sanctions law that would have allowed heavy tariffs on countries buying Russian crude or helping Moscow evade sanctions. Kazakhstan was one of the countries that could have been hit.
A Central Asian diplomat summed up the region’s mood: officials are unsure how far Washington will keep pursuing Russian sanctions evasion. That uncertainty is now the most valuable thing Central Asia brings to the negotiating table. And Washington handed it over itself.
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Since 2022, Central Asia has been a key back door for goods Russia’s war economy needs. Kazakhstan’s exports to Russia of items on the West’s high-priority dual-use list, which covers chips, machine tools and drone parts, jumped by more than 400% in 2022. They fell sharply over the following two years under the threat of secondary sanctions (penalties on third-country firms that deal with sanctioned Russian entities), yet some flows through Kazakhstan, Kyrgyzstan and Uzbekistan rose again in 2025. The same research found Kazakhstan’s government was not systematically complicit. The problem was the region’s open border with Russia and its membership of Moscow’s customs union, not policy in Astana. That made enforcement a matter of incentives, and incentives depend on expectations.
Then Washington changed direction. On 9 October it struck a deal to import Russian diesel. On 16 October Trump paused, by executive order, the Graham–Blumenthal sanctions law he had signed a month earlier. That law authorised tariffs of up to 100% on the biggest buyers of Russian energy. Meanwhile, the US is courting the same region for tungsten, rare earths and uranium. Last November’s White House summit with Central Asian leaders produced $25bn in announced deals, including a $1.1bn tungsten project in Kazakhstan.
The Price of Predictability
The usual critique is that sanctions are leaky. That is true, but it misses what actually happened this month. Sanctions never stop all trade. They work by changing how firms and governments in third countries calculate risk. A Kazakh distributor deciding whether to ship machine tools to a Russian buyer is not reading the law. They are estimating how likely it is that someone will enforce it two years from now. That estimate is the real currency of sanctions, and this month Washington devalued it.
It helps to separate exemptions written into the rules from exemptions granted at someone’s discretion. Sanctions regimes have always had carve-outs. Kazakhstan’s oil, about 80% of which reaches the world through Russia’s Caspian Pipeline Consortium to the Black Sea, has been exempt from Western measures throughout the war. Nobody thinks that weakens the regime, because the exemption is written down, stable and the same for everyone. A pause signed two days before the law took effect, announced alongside a diesel deal and timed before an election, is different. It tells every third country that US enforcement depends on fuel prices, the electoral calendar and whatever deal is on offer. Once enforcement is understood as a variable, it can be negotiated.
Central Asian governments are good at exactly this kind of negotiation. Consider what Kazakhstan can offer each power. To Washington it offers minerals, Boeing orders, and its agreement last November to join the Abraham Accords. To Moscow, Astana has given Rosatom the contract for its first nuclear power plant, with Russia expected to finance 85% of it. To Beijing it offers the transit corridor and the alternative export routes China wants. Each deal is a reason for one capital to ask the others for more. When Washington’s sanctions stance was firm, it limited how far Astana could tilt toward Moscow. That limit is now itself something Astana can bargain over: tighter compliance in return for investment, looser compliance as the price of keeping Russia on side.
The strongest objection is that this overstates the change. The US Treasury still sanctions Central Asian firms, and Astana’s export licences remain in force. That is true, but enforcement is shifting to someone else. The European Union has become the more predictable enforcer. In July its 21st package put two Kazakh firms and three Kyrgyz firms under export controls, banned dealings with a Kyrgyz bank, and earlier this year it used its new anti-circumvention tool against Kyrgyzstan. A compliance officer in Almaty now has more reason to read Brussels’ rulebook than Washington’s. As Modern Diplomacy has noted, the EU’s record Russia blacklist is increasingly what defines the financial war. The paradox is that America is wooing a region with deals while Europe sets the rules of the sanctions regime.
There is also a cost to Washington that goes beyond Russia. A secondary-sanctions threat is a bluff that has to be believed to work. Once third countries see that the threat can be traded away, every future US threat costs more to make credible, whether it targets Russia, Iran or China. The diesel deal may have lowered fuel prices before the midterms. It also lowered the value of every sanctions threat Washington will make afterwards.
How the Region Plays It
Base case (55%): two-speed enforcement. Washington pursues deals and stays quiet on evasion, while Treasury occasionally designates small intermediaries to show it still enforces. Central Asian governments follow EU rules where European markets matter and accept modest increases in dual-use flows to Russia elsewhere. The key assumption is that the pause holds beyond the midterms, with no override from Congress.
Downside case (25%): enforcement as punishment. After 3 November, Congress narrows the pause or Trump revives the tariff threat, but uses it selectively as leverage in unrelated trade talks rather than against evasion as such. Firms that relaxed their compliance in the gap are exposed. The lesson the region draws is worse than inconsistency: US sanctions follow political convenience, not the evidence. India, Rubio’s next stop, would face the same threat. A sanctions tool that once had a clear target becomes something wielded in tariff negotiations. For businesses, that means compliance costs rise while protection does not, because staying compliant no longer guarantees staying safe.
Alternative case (20%): compliance written into the deals. Washington turns its minerals push into leverage, attaching end-use and export-control commitments to US financing and offtake agreements (contracts to buy a project’s future output) in Central Asia. Enforcement would then become a condition of commerce rather than a political mood. This is the most promising path, and it is plausible because the region wants the investment more than it fears the sanctions.
Probabilities reflect the author’s analytical judgment based on currently available information and are not statistical forecasts.
The Samarkand Test
Sanctions are only as strong as third countries’ expectations about enforcement. This month Washington showed Central Asia that its enforcement can be negotiated. Kazakhstan and its neighbours will not openly defy Washington. They will bargain, trading compliance against Moscow’s financing and Beijing’s markets, while gradually loosening Russia’s hold on their own terms.
The signal to watch is Monday’s C5+1 statement in Samarkand. If it mentions export controls or sanctions compliance alongside minerals, Washington is still treating enforcement as a rule. If it mentions only minerals and connectivity, the region will conclude that enforcement is now something it can negotiate, and it will negotiate accordingly. Moscow will notice too. Sanctions are meant to make countries ask whether they can afford to help Russia. Washington has now taught them to ask what that help is worth, and to whom.
