The Swiss Federal Council decided to implement additional sanctions against Russia on 29 March 2023.

The Swiss Ordinance on Measures in Connection with the Situation in Ukraine has been amended accordingly. This aligns Switzerland with the European Union, which adopted its tenth package of sanctions on 25 February 2023. In addition to humanitarian exemptions, the most recent measures introduce a new means of protecting Switzerland’s economic interests in specific instances as the Federal Council emphasised in its press release. The amendments entered into force at 8 p.m. on 29 March 2023.

In addition to changes to the reporting requirement in the financial sector, the latest new sanctions include a ban on Russian nationals serving on the governing bodies of owners or operators of critical infrastructure as well as additional sanctions regarding goods. Specifically, there are new bans and restrictions on a variety of exports, such as dual-use goods, goods that contribute to military and technological advancement or the development of the defense and security sector, goods that contribute to Russia’s industrial capacity, and goods used in the aviation and aerospace industries. The latest package also tightens import restrictions on goods of economic importance to Russia.

Furthermore, the Federal Council has made a modification regarding humanitarian exemptions. The Federal Council has issued a humanitarian exemption for the provision of certain services to Russian organizations, following its decision on 3 March 2023 to facilitate humanitarian activities in Syria. This exemption applies to public bodies or organizations in Switzerland that receive federal funding for their humanitarian activities.

In addition, the Federal Council introduced the possibility of authorizing the transfer of funds or economic resources to sanctioned individuals, companies, or organizations on a case-by-case basis, if deemed necessary to protect Swiss interests. This decision was prompted by the need to prevent two sanctioned Russian banks from acquiring shares in two Swiss companies, Sulzer and medmix AG. As a result of US sanctions imposed on Viktor Vekselberg in 2018 and Switzerland’s sanctioning of two Russian banks, Tiwel Holding AG (major shareholder of Sulzer and medmix) was no longer able to service its loan with the Russian banks – a loan for which Tiwel’s shares in Sulzer and medmix serve as collateral.