Switzerland: Swiss Sanctions Against Russia – Adoption Of Further Measures

The Swiss Federal Council continues aligning the Swiss sanctions regime to the EU sanctions against Russia. On January 25, 2023, the Swiss Federal Council enacted further sanctions against Russia, in line with the 9th sanctions package adopted by the European Union (EU). The new measures relate to bans on product testing, advertising, market research and opinion polling services, as well as the export ban on aircraft and drones. In addition, new investments in the Russian mining sector are now prohibited.

1. Introduction

On January 25, 2023, the Swiss Federal Council adopted further sanctions against Russia with a view to mirroring the latest measures imposed by the EU on December 16, 2022. The corresponding amendments to the Ordinance on measures in connection with the situation in Ukraine ("UKRO")¹ entered into force on January 25, 2023 at 18:00 CEST.

The new measures include bans on product testing, advertising, market research and opinion polling services, and new controls and restrictions on the export of various goods, including dual-use goods, goods for military and technological enhancement, or for the development of the defense and security sector, or goods that contribute to the enhancement of Russian industrial capacity. In addition, the export ban on goods for the aerospace industry has been extended to include engines for aircraft and drones. Likewise, new investments in the Russian mining sector are now prohibited.

In this context, it is worth mentioning that a new extensive definition of the mining sector was introduced in Art. 1 UKRO, which includes the location, extraction, management and processing of non-energy mining products, including stone and earth extraction.

Finally, certain reporting obligations are introduced in relation to the import of natural gas from Russia to Switzerland.

The below provides a summary overview of the most notable restrictions in force today. The corresponding changes introduced since our last update are highlighted in red.

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Footnote

1. A free English translation and a redline against the version of December 16, 2022 are available, respectively here and here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.