UK warns: businesses in Georgia and Armenia aiding Russia’s sanctions evasion will be sanctioned

UK to Georgia and Armenia regarding Russia sanctions

The UK government has published special guidance for non-British businesses operating in Georgia, Armenia, Kazakhstan, Uzbekistan, and Kyrgyzstan. The document aims to help local entrepreneurs understand the UK’s sanctions against Russia and how violations could affect their business operations, including outside the UK.

The document, available on the UK government’s official website, outlines practical steps and provides concrete examples of what constitutes assistance in evading sanctions. It clearly states: anyone helping Russia circumvent sanctions will themselves be subject to sanctions.

The British Embassy in Georgia published a post on its Facebook page, stating: “The UK has published new sanctions guidance to support businesses in Georgia. The guidance aims sets out Georgian and UK laws relevant to sanctions and identifies practical steps for businesses to manage sanctions risks and promote compliance.”

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Summary of the UK’s new guidance on sanctions compliance regarding Russia

The document outlines several tactics used by Russia to circumvent sanctions, including:

• Indirect delivery routes
• Falsification of end-user destinations
• Professional evasion networks

According to the guidance, this may involve the following scenario:

• A company operating in Georgia receives an order from a Russian importer for goods that fall under UK sanctions and therefore cannot be delivered directly from the UK.
• The local company then orders the goods from a UK supplier without informing the supplier—or other relevant parties such as banks, insurers, or freight companies—that the final consumer is in Russia.
• The UK supplier exports the goods to the local company, which subsequently re-exports them to Russia.

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The guidance also outlines the risks that may affect local businesses.

While only UK nationals are legally required to comply with UK sanctions, non-UK nationals who help circumvent them face certain risks, including:

• The UK may impose sanctions directly on you as an individual or on entities you own or control if you are involved in activities that support Russia’s invasion of Ukraine.
• Even if you are not a UK national, being sanctioned by the UK can have serious consequences for your business and financial operations. UK sanctions apply to UK citizens and entities worldwide.
• Every UK bank—and many international banks—may freeze your assets and deny you any services.
• If UK companies are part of your insurance or shipping/freight supply chain, they will also refuse to work with you if you or any related party or goods are under sanctions.
• According to the guidance, as a result of the above, many UK companies will refuse to do business with such individuals or entities unless they can prove they have taken effective steps to prevent any goods or services from being forwarded to Russia or to Russia-linked parties.

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