Asset freezes and the companies of Zug

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The sanctions against Russia include the freezing of the assets of designated persons and entities and the prohibition of making funds and economic resources available to them. For a canton with more than 38,000 registered companies, many of them owned by foreign persons, the asset freezes have practical consequences. Companies in Zug that are owned or controlled by designated persons are subject to the freeze. Their assets, including bank accounts, real estate and participations, may not be used or disposed of without an authorisation of SECO. Their directors and service providers may not make funds or economic resources available to the designated owners.¹

The determination of ownership and control is a central question. A company in which a designated person holds a majority of the shares, or which he controls through other means, is treated as controlled by him. Its assets are frozen even if the company itself is not designated. The practitioner must therefore look through the corporate structure to the ultimate owners, a task that the new transparency register, described in Part C, will facilitate for the authorities but that the service providers must perform themselves. Several companies in Zug with Russian owners have been affected by the freezes. Their directors, often Swiss residents who serve on their boards, have had to decide whether to remain in office, how to report to SECO and how to manage companies whose owners cannot be paid. Part I returns to these cases.

Notes

Art. 15 paras. 1 and 2 and Art. 16 of the Ordinance of 4 March 2022 on Measures in connection with the Situation in Ukraine (SR 946.231.176.72), droit-bilingue.ch: funds and economic resources owned or directly or indirectly controlled by the persons, companies and organisations listed in Annex 8 are frozen; it is prohibited to transfer funds to them or to make funds and economic resources directly or indirectly available to them; persons and institutions that hold or manage such funds or know of such economic resources must report them to SECO without delay, stating the beneficiaries and the nature and value of the assets. ↩

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 September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Asset freezes and the companies of Zug

Notes

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