The FBRC editorial team continues to investigate the export schemes for bovine animals (cattle) through the territory of Kazakhstan. The final part will address the geography of the potential scheme, which spans several countries at once.
In the first two parts of the investigation, we showed how Russian internal veterinary certificates can be used for export to countries outside the Eurasian Economic Union (EAEU), how single documents for multiple vehicles hinder traceability, how electronic documents are cancelled after the cargo has been dispatched, and how 42-day gaps in dates could indicate backdating. All these elements combine into a potentially systematic practice. But where exactly are the key points of the possible scheme located? And who is servicing it?
Earlier, our editorial team also released a series of investigations about potential schemes in the export of meat products and live animals, as well as about fictitious inspections in markets, the concealment of anthrax outbreaks and the illegal trade of saiga meat. Furthermore, we wrote about how the country's veterinary safety system, controlled by the Ministry of Agriculture, allows the import of potentially unsafe products.
TURKESTAN JUNCTION
The attentive reader has probably already noticed that the systematic passage of cargo through veterinary control points in the Turkestan region involving the same officials can be traced in many of the previously presented documents.
The Veterinary Control Point (VCP) "Kazyghurt auto" in the Turkestan region, for example, appears in the inspection reports accompanying the certificates dated 25 November. The first is accompanied by reports from the VCP "Kosak" dated 26 November, signed by veterinary inspector Bazarbai Sapenov, and "Kazyghurt auto" dated 29 November, signed by chief specialist Zhambyl Omarov. 
The second is accompanied by reports from the VCP "Kosak" dated 27 November and "Kazyghurt auto" dated 29 November, signed by the same officials.
The VCP "B. Konysbaev" in the Turkestan region appears even more frequently. For example, a report dated 28 November for a certificate for 375 head was drawn up by chief specialist Batyr Moldabekov in the presence of veterinary sanitary inspector Mr. Sambetov. Meanwhile, a report dated 30 November was signed by chief specialist Yerzhan Dospulov. 
All veterinary sanitary inspection reports note the full compliance of the relocated object with the accompanying documents, and the conformity of temperature, organoleptic indicators, packaging, labelling and the veterinary-sanitary condition of the vehicles to the established requirements. The absence of clinical signs of disease in the animals is stated.
It should be noted that the operation of these posts falls under the responsibility of the territorial department of the Veterinary Control and Supervision Committee of the Ministry of Agriculture for the Turkestan region, which coordinates their activities in accordance with the regulations of the central committee. This systematic nature of cargo passing through controlled posts inevitably raises doubts about the thoroughness of the regional control being exercised.
TRACK THROUGH BELARUS
Of particular interest are the marks relating to the Republic of Belarus on documents whose route, according to the primary certificates, should pass through Kazakhstan.
For example, in the veterinary certificate series dated 23 November for 225 head, the sender is LLC "Merkit" in the Altai Republic, and the consignee is LLC "Marmari" in the Khatlon region of Tajikistan. Route: the village of Yakonur through Kazakhstan to Uzbekistan. Attached to this single veterinary certificate are three separate international CMR consignment notes, each for the transport of 75 head. On all three consignment notes, in section 16, stamps are affixed with the text "Transport Private Unitary Enterprise", "REPUBLIC OF BELARUS", "BELARUS". On CMR note 220, the organisation name "MEGASILA" can be read.
The appearance of Belarusian marks on documents, whose route should pass through Kazakhstan to Tajikistan/Uzbekistan, may indicate the involvement of vehicles from the territory of Belarus in the scheme, which is not reflected in the primary veterinary certificate.
SYSTEMATIC NATURE AND GEOGRAPHY
The repetition of certain names, organisations and geographical points may indicate the systematic nature of the described practice.
For instance, veterinarians from the Ust-Kan District Station for Animal Disease Control regularly issue certificates for large consignments involving multiple vehicles. And LLC "Merkit" appears as the sender in most cases known to us: in certificates for 200, 120, 225, 375 and 400 head. In all these cases, according to the documents, the route passes through Kazakhstan to Uzbekistan or Tajikistan, with the point of departure being the village of Yakonur in the Ust-Kan district of the Altai Republic.
As is known from previous parts of the investigation, the veterinarian Ms. Kryukova issued three certificates dated 26 November for batches of 30 head each. All three with cancelled EVSD, all with the same official consignee, all with an actual route, according to the consignment notes, through Kazakhstan to Tajikistan. The sender in all cases is LLC "Agropromkomplektatsiya-Kursk", branch "Farm for rearing and fattening young cattle" in the village of Zhilino, Zheleznogorsk district.
And the state veterinary inspector Mr. Shumashinov, on behalf of the Rosselkhoznadzor administration for the Altai Territory and the Altai Republic, repeatedly stamped and marked "Release permitted" on documents with the described registration peculiarities. Uzbek consignees also repeat time and again in the certificates for hundreds of transported head.
All animals are identified by electronic ear tags with the prefix RU1, which corresponds to the Russian identification system. However, according to the source, this does not exclude the possibility of legalising livestock of unclear origin through the issuance of Russian certificates followed by transit through the territory of the Russian Federation.
CONCLUSION: HOW THE SCHEME COULD WORK
What do we have? The mechanisms of the scheme include the use of single documents for multiple vehicles, the cancellation of electronic accompanying documents after dispatch, chronological inconsistencies and systematic passage through the same veterinary posts.
Between the senders and the veterinary services, based on the nature of the documents, there may be intermediaries - individuals who coordinate the preparation of the necessary paperwork, ensure the passage of cargo through specific posts, and organise reloading along the route. The recurrence of the same senders, consignees, veterinarians and border posts may indicate the existence of stable connections between participants in the potential scheme.
A key element of this practice is the veterinary posts at the border, where the primary inspection should take place. The task of border control is to check documents against the data in the "Mercury" system, verify the availability of international veterinary certificates for export, ensure the legality of transit, check vehicles and drivers, and confirm the validity of documents. However, the systematic passage of cargo with the described peculiarities may suggest that these checks are either not carried out properly, or their results do not influence the decision to allow passage.
The clearance of vehicles using cancelled electronic documents, the lack of response to the absence of international certificates, and the ignoring of date inconsistencies - all this can only happen systematically under certain conditions. An isolated incident could be a mistake. A regular practice requires, at a minimum, an absence of proper oversight.
The territorial administrations of veterinary services in the regions are obliged to supervise the work of subordinate posts, conduct inspections, track anomalies in document flow, monitor cancelled electronic documents, verify transit routes, identify atypical reloading, and analyse export statistics. The systematic passage of large consignments with the described peculiarities through the same posts in the Turkestan region may raise questions about the quality of such oversight.
At the republican level, responsibility for the functioning of the veterinary control system lies with the Committee for Veterinary Control and Supervision of the Ministry of Agriculture. The Minister of Agriculture, Aidarbek Saparov, as the head of the department, is responsible for the work of the entire subordinate structure, including the veterinary control system at the borders. In turn, the scale of the potential practice, the breadth of its geography, and the regularity of such cargo passing through inevitably raise questions about the sufficiency of systemic control measures, as well as whether this situation was timely noticed and properly assessed at the ministry level.
The Ministry of Trade and Integration, headed by Arman Shakkaliyev, also plays an important role in the overall picture, as the department oversees issues of cross-border trade and the transit of goods. Coordination between veterinary and customs control is critically important for preventing illegal schemes. The systematic passage of cargo with dubious documentation may indicate gaps in inter-departmental cooperation.
Incidentally, according to information from our sources, it was Mr. Shakkaliyev who initiated the temporary restrictions on the export of bull calves and livestock in May, with the Ministry of Agriculture allegedly siding with farmers on this issue, while the Ministry of Trade insisted on the ban. We are not asserting anything, but such schemes themselves allow for certain conclusions to be drawn.
The geography of the potential scheme covers the Altai Republic, Kursk Oblast, the Kabardino-Balkar Republic, Altai Krai, and Orenburg Oblast in Russia; the Abai Region and Turkestan Region in Kazakhstan; Andijan and Bukhara regions in Uzbekistan; and the Khatlon region in Tajikistan. The recurrence of officials, senders, routes and registration methods points not to isolated incidents, but to a potentially well-established practice, in which veterinary control could be transformed from a barrier into a mechanism facilitating the movement of livestock of unclear origin.
Ultimately, we are presented with a picture in which the oversight mechanisms intended to ensure the transparency and legality of cargo movement may not simply be ineffective, but potentially embedded within the scheme for its unimpeded transit. When such routes become the norm, rather than the exception, the question is no longer one of oversight