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Switzerland’s Sanctions Related to the Situation in Ukraine

Authored by our Global Sanctions Team

On 28 February 2022, the Swiss Government decided to adopt the sanctions imposed by the EU on 23 and 25 February 2022. The assets of sanctioned individuals and companies are frozen with immediate effect. The financial sanctions now extend to Russian President Vladimir Putin, Prime Minister Mikhail Mishustin and Foreign Minister Sergey Lavrov. The issuance of certain financial instruments is prohibited.

 

Measures

Switzerland has amended its 'Ordinance on measures to prevent the circumvention of international sanctions connected with the situation in Ukraine' (now 'Ordinance on measures in connection with the situation in Ukraine') which was first issued 2014.

Switzerland has implemented the following new sanctions:

  • Asset freeze:
    • The assets belonging to or under the control of individuals, companies and entities listed in Annex 3 of the Ordinance are frozen with immediate effect (the list includes Russian President Vladimir Putin, Prime Minister Mikhail Mishoustin, Foreign Minister Sergei Lavrov and the members of the Russian parliament). The SECO may exceptionally authorize specific transactions in limited cases.
    • It is prohibited to provide directly or indirectly assets or economic resources to the individuals, companies and entities listed in Annex 3.
    • Entities that hold or manage assets that should be frozen must be declared them to the SECO.

Switzerland reinforced the following existing sanctions:

  • Financial restrictions:
    • Ban on the issuance of certain financial instruments (and related assistance) with maturity greater than 30 days issued by specific targeted banks and entities in Russia or, banks and entities outside of Switzerland controlled by those targeted banks and entities or acting on their behalf or under their instructions. Some exceptions are provided.
    • Ban on the issuance of financial instruments (and related assistance) issued by Russia, its government, the Central bank of Russia, or any legal person, entity or body acting on their behalf or under their instructions.
    • Ban on the granting of certain loans (directly or indirectly) with maturity greater than 30 days to specific targeted banks and entities in Russia or, banks and entities outside of Switzerland controlled by those targeted banks and entities or acting on their behalf or under their instructions. Some exceptions are provided for loans agreed before 28 February 2022.
    • Prohibition on the trading of certain financial instruments.
  • Measures concerning specific territories:
    • The ban on imports, exports and investments concerning Crimea and Sevastopol, which has been in place since 2014, has been extended to the areas of the Ukrainian oblasts of Donetsk and Luhansk not controlled by the Ukrainian government.

The following commercial restrictions which were decided in 2014 remain in force:

  • Restrictions relating to dual-use goods and specific military goods.
  • Ban on the import of firearms, ammunition, explosive materials, pyrotechnics and powder of war from Russia or Ukraine.
  • Mandatory declaration for certain goods and services of the petroleum industry.

 

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