The content of the sanctions

Read the PDF edition (2 pages)

The sanctions adopted by Switzerland comprise financial measures, trade measures and measures against persons. The financial measures freeze the assets of listed persons and entities and prohibit making assets available to them. They also restrict transactions with the Russian central bank, prohibit certain financial services and limit deposits from Russian nationals.¹ The trade measures prohibit the export of goods and technologies that could strengthen Russia's military and industrial capacity as well as the import of Russian oil, coal, steel, gold and other goods. The measures against persons include travel bans and the freezing of assets of listed oligarchs, officials and companies.

The measures that affected the traders of Zug most directly were the prohibitions on the purchase, import and transport of Russian commodities. The European Union prohibited the import of Russian coal from August 2022, of crude oil transported by sea from December 2022 and of petroleum products from February 2023. It also introduced, together with the G7 states, a price cap on Russian oil, under which European and Swiss companies may provide services such as trade finance, insurance and shipping for Russian oil sold to third countries only if the price does not exceed a set level.² Once Switzerland had adopted these measures as well, Swiss-based traders could continue to trade Russian oil to third countries within the price cap, but the risks and the compliance costs made most of them withdraw.

Notes

Ordinance of 4 March 2022 on Measures in connection with the Situation in Ukraine, SR 946.231.176.72, original version AS 2022 151, fedlex.admin.ch: freezing of funds and economic resources (Art. 15), prohibition on accepting deposits of more than CHF 100,000 per bank from Russian nationals and residents (Art. 20), prohibition of transactions relating to the reserves and assets of the Central Bank of the Russian Federation (Art. 24). The prohibition of trust services was added later (see below). ↩
Germany Trade & Invest, "Chronologische Übersicht über EU-Sanktionen gegenüber Russland", gtai.de: 5th package (8 April 2022) with coal import ban effective 10 August 2022; 6th package (3 June 2022) with crude oil embargo from 5 December 2022 and petroleum products embargo from 5 February 2023; 18th package (18 July 2025) lowering the crude price cap from USD 60 to USD 47.60. Wikipedia, "Russian oil price cap", en.wikipedia.org: cap set at USD 60 per barrel on 3 December 2022, in effect from 5 December 2022, products cap from 5 February 2023; Switzerland joined the price cap coalition on 8 December 2022. ↩

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 October 2026.

English

Contact

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.

Get in touch →

The content of the sanctions

Notes

Setting up or expanding in Switzerland?