On 26 June 2025, the FCDO published new guidance on UK sanctions compliance for non-UK companies, including businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan.
Notably, the guidance explicitly references secondary sanctions measures targeting businesses in third countries (BTCs) that help Russia circumvent restrictions. The guidance confirms that BTCs suspected of involvement in such activity risk being designated under the Russia Regulations, cutting them off from UK dealings and prompting wider “de-risking” by international businesses.
The FCDO also reminds UK companies of their responsibility to prevent goods or services from being diverted to sanctioned entities, and that it expects robust due diligence and compliance measures to be in place.
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