Boeing vs. Sanctions: Can Russia Benefit from Uzbekistan’s Order for 22 New Aircraft?

In 2025, Uzbekistan’s national carrier, Uzbekistan Airways, signed the largest contract in its history to purchase 22 Boeing 787-9 Dreamliners worth more than $8 billion according to the parties’ estimates.

At the same time, air traffic with Russia increased sharply: in 2024 alone, 32,565 flights were operated between Uzbekistan and Russia, carrying more than 4.1 million passengers. A coincidence? Let’s break down where there is a real threat to the sanctions regime and where it is just conspiracy thinking.

What Is Banned in Russian Aviation

After 2022, the US, EU, and the UK introduced a whole set of restrictions against Russian civil aviation:

• A ban on supplying aircraft and spare parts to Russian airlines
• Aban on leasing and insuring aircraft for Russian operators
• A ban on Russian carriers flying through the airspace of the EU, US, UK, and several other countries
• A requirement for a “no Russia / no Belarus clause” in new export and leasing contracts, meaning the aircraft cannot be used in the interests of Russian entities or on Russian territory

This severely limits Russia’s ability to purchase aircraft both directly and via leasing. There have also been major issues with aircraft insurance and maintenance, including through third countries.

Tashkent’s Potential

Uzbekistan is officially not part of Western sanctions against Russia and is actively expanding its economy through transit and logistics. Analysts and Western media have already noted that Central Asia overall has become an important route for bypassing restrictions, primarily in industrial goods and technology.

Against this backdrop, Uzbekistan Airways is acquiring a fleet of long-haul 787-9s, sharply increasing the number of flights to Russia, and positioning Tashkent as a transit bridge between Russia, Europe, and Asia.

This in itself does not violate sanctions. But it creates infrastructure that Russia could potentially use to circumvent them. Let’s look at this situation from different angles.

How Russia Could Bypass Sanctions

Hidden aircraft operation

In 2025, Russia’s State Duma legalized the use of wet-lease for Russian airlines — leasing aircraft with crew from foreign carriers.

In theory, the scheme could work like this:

• An Uzbek carrier (or its subsidiary) leases part of its fleet for charters serving Russian tour operators
• The actual route and passenger flow serve the Russian market, while legally the aircraft belongs to the Uzbek side
• If Boeing / Eximbank / lessors do not have strict “no Russia” restrictions in the contracts or if they are poorly enforced, this becomes a way to partially relieve sanction pressure on Russia

But the EU and US have inserted strict rules for Russia into standard contracts.

Regulators directly require manufacturers and lessors to track the final use of aircraft.

Passenger Transit

• A Russian passenger flies on a domestic route to Uzbekistan
• Then from Tashkent, Uzbekistan Airways carries them to Europe, the US, or Asia

Sanctions do not prohibit Russians from flying through third countries. But Western politicians may view this as an alternative corridor for Russians.

Spare Parts and Maintenance

Another risk is the re-export of aircraft parts. In 2025, an investigation by The Guardian showed that companies from several countries (including India) bought spare parts from Western manufacturers and resold them to Russia.

Given that Central Asia has long been considered a channel for bypassing sanctions, such a scenario is theoretically possible. However, aircraft and their parts are not the same as washing machines or cars.

They are subject to much stricter control by the lessor, the bank financing the deal, and Boeing itself. Because of this, we would not place much confidence in this option.

A large 787 order in a country that has sharply increased air traffic with Russia, and is already mentioned in discussions about sanctions evasion, does warrant increased regulatory attention.

At the same time, it is important to consider that Tashkent has already become Central Asia’s main air hub (something Astana never fully achieved), and strengthening this role with new long-haul aircraft and expanded air links with Russia is a logical step in building the country’s transit potential.

What Checks Exist?

Could Uzbekistan help Russia bypass sanctions through such a deal? Yes. But first, by that logic, Kazakhstan could also help Russia, as it signed a similar lease deal for 15 Boeing 787-9 Dreamliners. Second, this would be very difficult, because the US has several layers of control:

US export control. All Dreamliners are US exports, so they fall under the Export Administration Regulations (EAR). The US directly prohibits transferring American aircraft to Russian operators — even indirectly, through third countries. Uzbekistan Airways must disclose to Boeing every sale, lease, or charter deal. End-use restrictions are imposed on how the aircraft can ultimately be used.

EU sanctions. Europe prohibits the use of European infrastructure (airports, insurance, payment processing) for flights that may bypass sanctions. So if the Boeings suddenly start flying to Russia 800 times a month, European insurers may refuse to provide coverage, making the operation of the aircraft illegal.

ICAO and international flight databases. The International Civil Aviation Organization tracks all flights, and if the Boeings suddenly start flying to Sochi, Yekaterinburg, or Kazan, this will be visible in real time.

Uzbekistan’s own regulator. Official monitoring in Uzbekistan has not been canceled. Formally, the Uzbek regulator must inform Boeing and the EU if the carrier changes how the aircraft are used.

Insurers and leasing companies. This is one of the strictest levels of control. Insurance companies require a list of routes, copies of sublease contracts, and confirmation of sanctions compliance.

It is also important to understand that any attempt to directly or indirectly help Russia would cause an immediate scandal at the level of Boeing and OFAC. If that happened, the country would not be able to purchase another Boeing again.

Original Author: Ilya Astakhov