On 14 July 2025, the United Kingdom's Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on Russia-related sanctions (the Guidance). The Guidance also includes tailored advice for businesses active in Kazakhstan, Uzbekistan, Kyrgyzstan, Georgia and Armenia, countries that are frequently used as transit points to circumvent Russian sanctions.
This move follows a broader global trend towards extraterritorial sanctions enforcement. The G7's 2024 finance communiqué emphasised closing enforcement gaps and maintaining frozen Russian sovereign assets, whilst the US Treasury has recently (in June 2024) expanded its secondary sanctions targeting foreign financial institutions that support Russia's war economy. Together, these developments signal a coordinated international effort to enforce sanctions extraterritorially and close loopholes to maintain pressure on Russia.
Why This Matters
Although UK law technically applies only to UK nationals and businesses, the Guidance warns that foreign entities can still face serious consequences if they are found to be facilitating the circumvention of UK sanctions. This includes actions like helping Russian parties obtain restricted goods or services such as by masking transactions through intermediaries. Potential consequences include the following:
- Asset freezes by UK institutions.
- Loss of access to UK markets and services.
- Reputational damage which could affect global operations.
What Should Businesses Do to Remain Compliant?
A proactive and risk-based approach is recommended. It is advised businesses do the following:
- Conduct risk assessments for red flags.
- Establish a clear, regular sanctions policy.
- Map supply chains to prevent diversion to Russia.
- Screen all partners and monitor UK designations (see the UK Sanctions List and the OFSI Consolidated List for regular updates).
- Check ownership and control structures of entities to uncover hidden links to sanctioned persons.
Conclusion
The Guidance marks an escalation in UK sanctions enforcement: Non-UK businesses—especially in logistics, commodities, machinery and finance—must act now. Non-UK businesses must strengthen their due diligence, screening and internal controls to avoid unintended violations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
