In a notable escalation of its Russia sanctions regime, the United Kingdom has sanctioned two of Georgia’s most prominent pro-government television channels — Imedi and PosTV, citing their role in disseminating pro-Kremlin narratives about the war in Ukraine.
The decision has prompted immediate questions both inside Georgia and abroad: What does this mean in practice? Will their assets be frozen? Can they continue operating as usual? How do sanctions function when the targeted entities operate entirely outside the UK?
This explainer lays out the legal framework and examines the likely financial consequences.
Why Were Georgian Television Channels Added to the UK Sanctions List?
The United Kingdom placed Imedi and PosTV under its Russia sanctions regime – the same legal framework applied to measures connected to Russia’s war against Ukraine.
Both outlets are major pro-government-leaning broadcasters in Georgia, playing a central role in the country’s domestic political media landscape. Imedi, in particular, has consistently ranked among the country’s leading television channels in national audience measurements and maintains significant nationwide reach.
According to the official sanctions notice, the UK government states that there are reasonable grounds to suspect that both media organizations qualify as “involved persons,” as their programming included narratives characterized as disinformation concerning Russia’s invasion of Ukraine and statements undermining Ukraine’s sovereignty.
This is an important legal classification. It means the entities are sanctioned not under media regulation law, but under a foreign policy and national security sanctions regime.
What Do Sanctions Mean in Practice?
The primary instrument of UK sanctions is an asset freeze.
Officially, this means that any financial resources or economic assets belonging to the sanctioned entity must be frozen. And no one may directly or indirectly provide funds or economic resources – including loans, credit, payments for services (such as advertising), or other services – without a specific license.
This is the central enforcement mechanism. An organization may continue operating domestically, but its ability to interact with the international financial system becomes significantly constrained.
These obligations apply directly to individuals and companies under UK jurisdiction (“UK persons”), even when transactions take place outside the United Kingdom.
Why Do UK Sanctions Have Global Effect?
UK sanctions are not confined to British territory. They apply to all UK nationals worldwide, all companies incorporated under UK law, and overseas branches of such companies.
This creates what is known as an extraterritorial effect: sanctions legally bind UK-jurisdiction entities wherever they operate. In practice, the impact is even broader because international financial systems compel banks and partners to avoid exposure to sanctioned entities to preserve access to global payment networks.
Will Imedi’s and PosTV’s Assets Be Frozen in Georgian Banks?
After the announcement, particular attention in Georgia focused on the country’s two largest banks — Bank of Georgia and TBC Bank — because of their links to the United Kingdom.
It is essential to distinguish clearly: neither institution is a British bank in operational terms. Both are Georgian commercial banks licensed and supervised by the National Bank of Georgia.
However, their parent holding companies — Bank of Georgia Group and TBC Bank Group PLC — are incorporated in the United Kingdom and listed on the London Stock Exchange. These holding companies fall directly under UK sanctions jurisdiction.
The two banks dominate Georgia’s financial system. Fitch has described Bank of Georgia as the country’s largest bank, with about 40% of sector assets, while industry reporting puts the combined share of Bank of Georgia and TBC Bank at around 76-78% of total banking assets in 2025. This high concentration means that compliance decisions by a small number of institutions can significantly shape how sanctions are implemented in practice.
UK sanctions obligations bind UK persons (UK nationals and UK-incorporated entities, including their overseas branches). Non-UK companies are not automatically “UK persons” solely because they are owned by a UK parent, but UK parents and UK-based decision-makers must ensure they do not breach sanctions through group activity.
What About Other Georgian Banks?
The impact does not concern only the two largest banks.
All Georgian banks rely on correspondent banking relationships, SWIFT messaging systems, foreign clearing networks, and international regulatory cooperation. In practice, the broader effect of sanctions arises from global compliance pressures. Banks and financial institutions must avoid transactions involving sanctioned entities in order to maintain access to the international financial infrastructure.
Because sanctions prohibit both direct and indirect provision of funds or economic resources, any bank that processes payments connected to sanctioned entities risks losing access to global financial channels.
For this reason, compliance risk, rather than local legal obligation alone, often determines bank behaviour.
Moreover, in an October 2024 interview on Georgian Public Broadcaster’s podcast “42nd Parallel,” Irakli Rukhadze – chairman of Liberty Bank and, until recently, owner of Imedi TV – stated that if senior officials were sanctioned, banks would be compelled to close their accounts because servicing sanctioned persons could threaten the institution’s existence.
Notably, in February 2026, Rukhadze announced that he would exit ownership of Imedi, transferring the channel to new shareholders, including Prime Media Global and senior management. He stated that media ownership no longer aligned with his investment focus, though the timing of the sale raised questions amid heightened geopolitical scrutiny.
The Prime Minister’s Call for Advertisers
Following the sanctions, Georgia’s Prime Minister publicly urged both state entities and private companies to continue placing advertising on the sanctioned broadcasters.
Domestically, this signals political backing.
However, international sanctions rules operate independently of political statements. For companies connected to the UK jurisdiction, advertising payments could potentially be interpreted as the provision of economic resources to a sanctioned entity, depending on the structure of the transaction and the jurisdiction involved.
This does not automatically mean advertisers are sanctioned. But it introduces legal and compliance risk for firms operating internationally.
What Is the Role of the National Bank of Georgia?
Sanctions enforcement became particularly sensitive in September 2023 when the United States sanctioned former Prosecutor General Otar Partskhaladze over alleged ties to Russian security services.
Initially, the National Bank instructed commercial banks to enforce restrictions in line with US, EU, and UK sanctions.
However, on September 19, 2023, the regulator amended its rule. Under the revised framework, foreign sanctions no longer automatically apply to Georgian citizens unless supported by a domestic court ruling – a decision justified on constitutional grounds, including the presumption of innocence.
Therefore, formally, foreign sanctions may require domestic legal grounding to be enforced locally. In practice, however, international financial networks frequently react independently of domestic regulatory interpretation.
Can National Regulation Shield the Channels?
International financial systems operate through interconnected networks rather than isolated national rules.
If any intermediary in a transaction chain identifies sanctions risk, it may block the payment.
For banks, the primary danger is not domestic litigation but loss of access to dollar or euro clearing systems and correspondent banking relationships. Even suspected sanctions violations can trigger severe consequences.
This leads to what financial experts describe as de-risking – institutions frequently applying sanctions more strictly than required to eliminate potential exposure.
What Does This Ultimately Mean?
UK sanctions do not mean that Imedi and PosTV will suddenly go off air. Their studios will continue operating, employees will still receive salaries, and domestic broadcasting inside Georgia is not directly affected.
What changes instead is their position inside the global financial system.
In modern economies, media organizations do not operate in isolation: they rely on international advertising markets and programming, cross-border financial transactions, payment infrastructure, and partnerships with global service providers.
Sanctions restrict access to these networks.
Legally, asset freezes inside Georgia are not automatic and would generally require domestic legal procedures. But in practice, international financial systems function through interconnected risk-management rules. Banks and counterparties tend to avoid any transactions involving sanctioned entities to protect their own access to global clearing systems.
This means that the most immediate impact of the UK measures is not operational shutdown, but financial isolation.
Over time, such isolation can and will affect investment flows, advertising revenues, international cooperation, and long-term sustainability.
For international observers, the significance is broader still: the sanctions reflect a growing shift in global policy tools. Increasingly, governments are treating information ecosystems – not only military or economic sectors – as strategic domains within geopolitical conflict.
