The Open Dialogue Foundation (ODF) welcomes the European Parliament’s efforts to develop accountability mechanisms using EU–Kyrgyzstan trade relations to address the transnational financial repressions through weaponisation of the financial sector and the misuse of anti-money laundering and counter-terrorism financing (AML/CFT) frameworks, SLAPP tactics by Kyrgyzstan.
We are particularly grateful to the European Parliament for recognising and supporting the work of the Open Dialogue Foundation,other civil society organisations and our donors, that enable our human rights, watchdog, and humanitarian efforts. The adopted on 9th September 2025 resolution on EU-Kyrgyz Republic Enhanced Partnership and Cooperation Agreement also highlights many aspects, particularly:
- Abuse of financial regulation frameworks – the resolution deplores the use of anti-money laundering and anti-terrorism legislation not for genuine risk management, but as tools to restrict access to funding, chill donor support, and silence dissent. It notes that ruling elites in Kyrgyzstan use state funds and national resources to consolidate power, silence critics, and resist reforms, instead of ensuring financial transparency or accountability.
- Stigmatisation and repressive oversight – the Russian-style “foreign representatives” law, targeting NGOs and independent media receiving foreign funding. These measures impose excessive reporting obligations, administrative barriers, and fines, effectively stigmatising and surveilling legitimate civil society actors and their donors.
- The Bakai Bank v. ODF case as a SLAPP – the resolution explicitly addresses the SLAPP lawsuit in Belgium brought by Bakai Bank OJSC Kyrgyzstan against ODF (page 8 and page 11). The Parliament condemns such attempts at legal intimidation to silence watchdogs, noting that:
– Bakai Bank seeks compensation amounting to EUR 1,050,000 in damages, plus additional financial penalties in the event of non-compliance with any future judgment;
– Bakai Bank waited 18 months after the publication of the reports before filing suit, suggesting a lack of immediate reputational damage;
– In July 2025, the Brussels Commercial Court rejected all provisional measures sought by the claimant to remove the 2023 ODF publications. - Politically motivated asset freezing and bureaucratic harassment, which serve as tools to persecute opposition figures, restrict NGOs, and suppress independent journalism.
- Risks related to EU funding oversight – the Parliament stressed the need for stricter monitoring of EU fund allocation in Kyrgyzstan to prevent political misuse and money laundering that harm both European donors and local human rights defenders.
The resolution also warns that financial repression targeting donors and civil society organisations leads to the isolation of civic space and undermines development cooperation and international partnerships.
Here are direct quotes from the European Parliament resolution confirming that donors or those who provide financial support to civil society and opposition are targeted and persecuted:
• “whereas the Russian-style ‘foreign representatives’ law, adopted by the Kyrgyz Parliament in March 2024, which requires non-profits that receive funding from abroad and engage in broadly defined political activity to register as ‘foreign representatives’, discriminates against and stigmatises journalists, human rights activists and other non-profit workers and subjects them to intrusive oversight, burdensome reporting requirements and excessive fines; whereas this law mimics repressive legislation in other authoritarian regimes and can be considered a precursor to further attempts to suppress independent civil society and media”
• “…urges the Kyrgyz Government to revoke the Russian-style ‘foreign representatives’ law, which severely impairs the ability of civil society to carry out legitimate public interest work and operate without undue interference and harassment while ensuring a safe working environment, and which contradicts Kyrgyzstan’s international obligations under the International Covenant on Civil and Political Rights and its commitments as an EU partner under the EPCA…”
• “…urges the Kyrgyz authorities to step up their efforts in eradicating corruption and not to use the fight against it as an excuse for cracking down on civil society and government critics”
• “Strongly condemns, and urges the Kyrgyz authorities to end, the ongoing and increasing crackdown on civil society and the efforts by Kyrgyz authorities to suppress independent media and limit public dissent through a combination of legal, administrative and coercive measures… expresses its admiration for Kyrgyz civil society and independent media which, despite the persecution and at great personal risk, remains one of the most vibrant civil societies in Central Asia”.
The European Parliament’s findings mirror a broader pattern consistently documented by the Open Dialogue Foundation: the increasing sophistication of transnational financial repression aimed at dissident voices, diaspora communities, civil society, and especially those who support them — most notably donors, including EU citizens. The most advanced and complex tactics of financial repression have been deployed across Central Asia, Turkey, the Gulf states, and are now increasingly encroaching on European Union territory.
Of particular concern is the use of the Chinese Geedge Networks surveillance system, implemented for instance in Kazakhstan, which enables unlawful and “terrifying” levels of digital content filtering, real-time monitoring, coordinated information blackouts, and targeted persecution of individuals based on their online activity. The Kazakh authorities after denying have publicly recognised the use of such technology to identify and locate government critics.
The Open Dialogue Foundation has itself become a target of this transnational financial repression and a Strategic Lawsuit Against Public Participation (SLAPP) not only from Kyrgyzstan, but from several states over the last 10 years. For instance, Kazakh security operatives have brought on Belgian soil a SLAPP case in retaliation for our work defending victims of political persecution and human rights abuses. Belgian court records confirm that Kazakh authorities deployed undercover officers — posing as ordinary citizens, but in fact active members of Kazakhstan’s police and security services — “to seek extensive personal surveillance data on both the Foundation and its President, Lyudmyla Kozlovska“. This coordinated operation aimed to obtain private travel, communications, and financial information on ODF and Kozlovska, spanning Belgium, the EU, and the United States.
The trend exposes not only vulnerable minority groups to heightened risk, but how this model undermines financial and data integrity, supply‑chain security, and the rule of law — risks that can spill into the EU via technology procurement, vendor interdependencies, and regulatory cooperation.
This alarming trend endangers not only human rights defenders and independent organisations but also the integrity of financial systems, data security, supply-chain resilience, and the rule of law across the European Union.
Read also:
- Brussels Court Rejects Attempt to Censor Sanctions Evasion Reporting (August 8, 2025)
- SLAPP & Transnational Financial Repression across Belgium/EU and the United States: The Case Against Lyudmyla Kozlovska and the Open Dialogue Foundation (June 11, 2025)
- The Price of Exposing Sanctions Violations: Bakai Bank’s Legal Attack on the Open Dialogue Foundation (March 4, 2025)
- Submission to the European Parliament and European Commission on the issue of sanctions circumvention (July 3, 2023)
- Russia’s Accomplices in the War Against Ukraine: Kazakhstan and Kyrgyzstan, the Russian Army’s Reliable Rear (May 9, 2023)
