Where Switzerland goes its own way

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The adoption has never been complete. When it implemented the eighth package in November 2022, Switzerland extended the arms embargo partly to Ukraine, because the law of neutrality requires equal treatment of the belligerents in the supply of war material.¹ In October 2024 the Federal Council declined to adopt the European obligation of "best efforts", under which parent companies must ensure that their subsidiaries in third countries do not undermine the sanctions. It reasoned that existing Swiss law already allows the prosecution of circumvention where payments or instructions are issued from Switzerland. It also declined the European restrictions on the registration of intellectual property rights by Russian applicants.² The ordinance has in turn introduced provisions of its own, such as Article 30f on claims for damages and protection of Swiss persons and Articles 30g and 30h on judgments and awards in investor–state disputes.³

The twentieth package illustrates the current position. On 19 August 2026 the Federal Council adopted it "according to previous practice". It extended the bans on services to liquefied natural gas tankers, icebreakers and Russian LNG terminals, prohibited the sale of tankers to Russia and, for the first time, activated the "anti-circumvention tool", which prohibits the export of sensitive goods to Kyrgyzstan. It also banned the use of Russian platforms for the transfer and exchange of Kryptowerte und Digital Assets. At that date about 2,790 natural persons, companies and organizations were subject to asset freezes in connection with the war against Ukraine.⁴

Belarus and the other regimes

Belarus has its own ordinance, which the Federal Council has amended in parallel with the Russian one. The first Belarusian measures adopted in March 2022 included import bans on wood, rubber, iron, steel and cement products, which matter for traders that bought Belarusian steel through Lithuanian ports before 2022.⁵ The measures of the nineteenth package against Belarus entered into force together with the Russian ones on 26 February 2026.⁶ Switzerland also maintains more than twenty other regimes, among them those concerning Iran, Syria, North Korea, Libya and Venezuela, each based on an ordinance under the Embargo Act. For a Ticino trader in metals or energy, Iran and Venezuela have been the most relevant beside Russia and Belarus, because of their oil and steel exports and because American secondary sanctions apply to both.⁷

Notes

1. White & Case, eighth package (above) ("For reasons of Swiss neutrality, the embargo will also be partially extended to Ukraine"). ↩
2. Baker McKenzie, "Swiss government implements further elements of the EU's 14th Russia sanctions package", Sanctions News, October 2024, https://sanctionsnews.bakermckenzie.com/swiss-government-implements-further-elements-of-the-eus-14th-russia-sanctions-package/. ↩
3. Ukraine Ordinance, Art. 30f–30h, table of contents (above). ↩
4. Federal Council press release of 19 August 2026 (above). ↩
5. Année politique suisse (above) (Belarus measures of 16 March 2022); Ordinance of 16 March 2022 on Measures against Belarus, SR 946.231.116.9, https://www.droit-bilingue.ch/de-fr/9/94/946.231.116.9-index.html. ↩
6. Federal Council press release of 25 February 2026 (above). ↩
7. SECO, "Sanktionsverordnungen", https://www.seco.admin.ch/de/sanktionsverordnungen (28 ordinances listed in October 2026, among them those on Belarus, Iran, Iraq and Libya). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.