Licences, exceptions and wind-down periods

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The sanctions contain exceptions and allow SECO to grant authorisations in specified cases. The sanctions regimes provide for wind-down periods for contracts concluded before the adoption of new measures, such as the period until 25 October 2026 for the import of Russian metals under contracts concluded before 24 July 2026 in the European package of July 2026. They allow the release of frozen funds to avoid cases of hardship and for the satisfaction of prior judgments and obligations under certain conditions. And they allow SECO to authorise transactions that would otherwise be prohibited, for example to ensure the supply of energy or to allow the orderly termination of business relationships.¹

For the practitioner, the exceptions and authorisations are important instruments. A trader that has concluded a contract with a Russian counterparty before the adoption of a new prohibition must determine whether a wind-down period applies and how long it lasts. A company in Zug whose owner has been designated must apply to SECO for the authorisations it needs to pay its employees, its rent and its taxes. Because the procedure is administrative, the practitioner's experience with SECO's practice, its expectations regarding documentation and its timelines is valuable to the client.

Notes

Source as cited in the printed edition. ↩

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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