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Monitoring of sanctions in Switzerland

1 марта 2023

1 March 2023

The European Union approved the tenth package of sanctions against Russia on February 26. Restrictions were introduced against 83 individuals and 33 legal entities from the Russian Federation. On 1 March Switzerland imposed sanctions against 120 individuals and entities from the EU's tenth sanctions list.

In connection with joining the tenth package of the European Union, Switzerland is implementing sectoral and blocking restrictive measures, including:

  • Prohibition of Russian persons to hold senior positions in critical infrastructure organizations;
  • Prohibition of transit through the territory of the Russian Federation of weapons and ammunition, as well as dual-use products subject to export control;
  • Establishing the obligation of aircraft operators operating regular flights between Russia and Switzerland to provide flight information to the Federal Aviation Administration 48 hours in advance;
  • Duty to provide some reporting.

The Swiss State Secretariat for Economic Affairs (SECO) has been authorized to issue individual permits to interact with persons subject to blocking sanctions if this is necessary for the interests of Switzerland. Each case will be considered individually.

The need for this measure is explained by the fact that two Swiss companies are obliged to return funding to sanctioned Russian banks in order to avoid the transfer of shares in the authorized capital of these companies that are pledged. Failure by Swiss companies to repay financing would lead to the right of creditors to foreclose on the collateral.

25 January 2023

On January 25, 2023, the Swiss Federal Council implemented the ninth package of EU sanctions.

the Swiss Federal Council, as part of the implementation of the ninth package of EU sanctions against Russia, decided to introduce additional restrictive measures.

The restrictive measures are contained in the decree of March 4, 2022:


 The restrictive measures introduced on 25 January 2023 include the following:

·         a ban on the provision of services in the field of product testing, advertising, market research, public opinion survey;

·         new measures of control and restrictions on the export of various goods, including dual-use goods, goods for military and technological improvement, development of the military-

industrial complex and goods that contribute to building up Russia's industrial potential;

·         extension of the aerospace export ban to engines for aircraft and drones;

·         a ban on new investments in the Russian mining sector.

At the same time the Swiss Department of Economic Affairs, Education and Research

(the “EAER”) imposed sanctions on an additional 200 individuals and entities.

According to the Decree of March 4, 2022, the ban on services in the field of product testing, advertising, market research, public opinion poll services does not apply to:

·         individuals (Appendix 25 to the Decree of March 4, 2022 contains a list of sanctioned persons);

·         Russian companies directly or indirectly owned by companies registered in the EU, Switzerland or the UK.


21 December 2022

On December 21, 2022, Switzerland renewed sanctions against Russia.

The following individuals were also included in the Swiss sanctions list:

·         National Media Group;

·         Credit Bank of Moscow;

·         PJSC "Far East Bank";

·         government agencies and a number of individuals.


02 August 2022

- Switzerland approved the seventh package of anti-Russian sanctions. It includes an embargo on the supply of gold from Russia.


29 June 2022

The Swiss Federal Council announced that Switzerland joins the sixth EU sanctions package adopted on June 3 2022. Switzerland imposes an embargo on crude oil and certain types of petroleum products of Russian origin. The purchase, import, transit, and transport of these products to or within Switzerland is prohibited.


28 April 2022

- Switzerland implemented the fifth package of EU sanctions. Sanctions were adopted on April 13, and two weeks later, changes were made to the relevant acts. It should be noted that Switzerland didn’t join the EU ban on the conclusion of public contracts with Russian persons (https://www.seco.admin.ch/seco/en/home/seco/nsb-news.msg-id-88265. html).


13 April 2022

- Switzerland adopted the fifth package of sanctions against Russia (https://www.reuters.com/world/europe/swiss-adopt-latest-round-eu-sanctions-russia-2022-04-13/) is identical to sanctions of the European Union approved on 8 April 2022. This package includes:

·         a ban on imports from Russia of coal, timber, cement, high-tech goods, seafood and others;

·         export of kerosene and other goods, including industrial equipment, robots and chemicals;

·         a ban on the participation of Russian companies in Swiss public procurement;

·         a ban on any form of financial and non-financial support for state institutions;

·         a ban on the provision of services to trusts;

·         ban on entry and transit to Russian and Belarusian transport enterprises;

·         asset freeze and entry ban for more than 200 people and companies from Russia.


16 March 2022

- On 15 March 2022 the EU approved the fourth package of sanctions against Russia. Switzerland imposed sanctions that are completely identical to EU sanctions. Thus, sanctions were imposed against 197 individuals (including Konstantin Ernst, Suleiman Kerimov and Tigran Khudaverdyan) and nine legal entities from Russia. Assets owned by the individuals in the list will be frozen (source: https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-87619.html).

Also subject of sanctions are:

·         Alexander Pumpyansky, TMK;

·         Dmitry Pumpyansky, TMK;

·         Alexander Vinokurov, Marathon Group;

·         Andrey Melnichenko, SUEK;

·         Dmitry Mazepin, Uralchem;

·         Mikhail Oseevsky, Rostelecom;

·         Mikhail Poluboyarinov, Aeroflot;

·         Sergey Kulikov, Rosnano;

·         Vadim Moshkovich, Rusagro;

·         Vladimir Kiriyenko, VK;

·         Andrey Guryev, Phosagro;

·         Dmitry Konov, Sibur.


07 March 2022

- Transactions with the Bank of Russia are prohibited, as well as the export of dual-use goods, products and services in the oil sector.

- The country joined the EU sanctions against the Russian financial sector.


02 March 2022

- Personal sanctions against V.V. Putin, M.V. Mishustin and S.V. Lavrov were introduced (travel restrictions).


28 February 2022

- All flights from Russia are banned, restrictions are imposed on Russian-owned aircraft (with the exception of diplomatic purposes, humanitarian, medical assistance).


Nadmitov, Ivanov & Partners law firm advises on sanctions.

Email: info@nplaw.ru

Tel: +7 (495) 649-87-12

+7 (495) 649-87-12