Key Takeaways: Secondary Sanctions—United Kingdom Issues Sanctions Guidance for Non-UK Businesses
By: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
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.
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