For many Nigerian companies, UK sanctions may seem distant. After all, these are British Laws, made by British institutions, mostly in response to issues like the Russia-Ukraine war. But that assumption is no longer safe. The UK government has now made it clear that it will go after not only companies operating in the UK or owned by UK nationals, but also non-UK businesses anywhere in the world, including Nigeria, if they are seen to be directly, indirectly, intentionally or unintentionally helping others avoid the sanctions, even unintentionally shipping UK goods or services to Russia. It should be noted that this is only in relation to specific actors contained in UK sanction list.
The UK Foreign, Commonwealth & Development Office (FCDO), working with the Office of Financial Sanctions Implementation (OFSI), has issued new guidance that makes one thing unambiguous: a business based outside the United Kingdom can face serious consequences under UK sanctions if it is found to be involved, directly or indirectly, in efforts to bypass those restrictions. UK authorities have already started investigating and in some cases sanctioning companies located entirely outside their territory.
At Legalify Attorneys, we have analysed the said UK Government’s sanctions guidance for non-UK businesses, and we offer clear, actionable guidance for businesses in international logistics, procurement, construction, oil and gas, tech, manufacturing, cross-border finance, or plays in the field contained in sanction lists.
