On 15 March 2022, the EU decided to impose further sanctions on Russia considering Russia’s ongoing military invasion of Ukraine. This fourth package of EU sanctions, in addition to the sanctions that have already been implemented, include more extensive measures in relation to goods, restrictions on transactions with certain state-owned enterprises and a ban on providing rating services to Russian clients or entities. In total, 877 individuals (including more than 30 oligarchs) and 62 entities are now on the EU sanctions list, according to the EU’s sanctions’ summary.

On 18 March 2022, the Swiss Federal Council took the decision to adopt a multitude of these new EU sanctions against Russia and to incorporate them into Swiss law. Accordingly, the Ordinance on measures in connection with the on the situation in Ukraine has been amended. The Federal Department of Economic Affairs (EAER) had already amended Annex 8 of the Ordinance on Measures connected with the Situation in Ukraine on 16 March 2022, thereby imposing the current EU sanctions on a further 197 individuals and 9 entities. Thus, Switzerland’s sanctions list corresponds completely to that of the EU. The Annex is published neither in the Official Compilation of Federal Legislation (Amtliche Sammlung, AS) nor in the Classified Compilation (Systematische Rechtssammlung, SR). The text can be ordered directly from the State Secretariat for Economic Affairs (SECO) or viewed here. According to the press release of the Federal Council, the ban on the export of luxury goods contained in the new sanction’s regime would affect only a small portion of Switzerland’s global exports of such goods. However, some specific companies might be seriously affected.

In addition, the withdrawal of the Most Favoured Nation (MFN) status for Russia under the World Trade Organisation (WTO) regime is part of the EU’s fourth sanctions package. The Federal Council announced that it will take its decision on that point based on an ongoing analysis conducted by the EAER.