UK Government Has Issued First Russian Sanction Guidance for Non-UK Businesses

The UK government published the first sanctions guidance on 27 June 2025, which aims to raise awareness among businesses in third countries that are seeking to avoid circumvention of UK sanctions.

The Foreign, Commonwealth and Development Office (FCDO) has provided comprehensive guidance for non-UK businesses in third countries for the first time.

This guidance is issued in multiple languages for non-UK businesses operating in Georgia, Armenia, Kazakhstan, Uzbekistan, and Kyrgyzstan. Separate guidance for each country is available on the official website.

The Main Objective Behind The UK Russian Sanction

The UK has implemented sanctions on Russia in response to Russia’s invasion of Ukraine.

The guidance report has clarified that Sanction Regimes aim to continue until Russia ceases activity that destabilises Ukraine and undermines its territorial integrity, sovereignty, and independence.

It also states that there will be no flexibility in sanctions regimes unless Russia promotes the payment of compensation for damage, loss, or injury that Ukraine has been suffering since February 2022.

The UK government will keep these sanctions in place until these objectives have been achieved.

So far, the UK government has officially sanctioned over 2,000 individuals and entities that have been involved in trade and economic activities with Russia.

While UK citizens and businesses have to comply with Sanctions imposed by OFSI (Office of Financial Sanctions Implementation), these sanctions now indirectly apply to non-UK businesses as well.

Businesses importing from the UK or having any commercial ties there are subject to UK sanctions enforcement. They are at risk of losing access to UK services if they deal with a person who is subject to sanctions or exports goods to Russia.

Further, third countries that aid in sanction circumvention are at high risk of being directly sanctioned by the UK. It will result in losing access to UK financial systems.

Russia may attempt to circumvent sanctions by using businesses registered in third countries. It can utilize them to re-export UK-restricted goods through deceptive practices. It may involve indirect shipping, falsified end-use claims, and evasion networks. These practices aim to obscure the Russian end-user from UK suppliers, banks, and shippers.

In case a non-UK business fails to comply with UK sanctions on Russia, it will have to face severe consequences. As FCDO guidance highlighted, breaching sanctions will result in severe penalties, asset freezes, loss of services, reputational damage, and direct UK sanctions.

Accordingly, for the businesses under UK jurisdiction or dealing with the UK, it is indispensable to ensure that goods or services they obtain from the UK aren’t diverted to Russia or sanctioned parties.

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This guidance provides a practical compliance framework and some steps for managing risks and protecting operations and business from severe disruption. They are conducting risk assessments, drafting sanctions policies, screening partners, and continuously monitoring for Russian links.