On September 14, 2026, the EU Commission adopted a Delegated Regulation updating Annex I to Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, the Delegated Regulation sets out the expected amendments to the EU Dual-Use Regulation. Background Annex I to the EU Dual-Use Regulation lists dual-use items that require an export authorization pursuant to Article 3(1) of the EU Dual-Use Regulation. The EU Commission periodically, usually at least…
On 19 August 2026, the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (the “Ukraine Ordinance”; the following citations in each case refer to the Ukraine Ordinance), thereby completing the implementation of the EU’s 20th sanctions package against Russia (see press release here). This final step follows the initial implementation step taken on 22 May 2026, when the Swiss Federal Council updated several Annexes to…
On 9 June 2026, European Commission President Ursula von der Leyen announced that the European Commission is preparing a 21st sanctions package against Russia, marking a further step in the EU’s ongoing effort to intensify economic pressure following Russia’s continued aggression in Ukraine. The proposed measures focus on high-impact sectors, including energy, financial services (including crypto-assets) and trade restrictions. Key Elements of the Proposed 21st Package Energy and Transport: Expanded Targeting of the Shadow Fleet…
Judgment 4A_537/2025 of 28 April 2026 In its recent judgment 4A_537/2025 of 28 April 2026, the Swiss Federal Supreme Court upheld the judgment of the Commercial Court of the Canton of Zurich of 17 September 2025 (HG230210-O) and provided important guidance on the interpretation of Swiss sanctions laws – specifically on the asset freeze and reporting obligations imposed on financial institutions holding or managing funds. The Swiss Federal Supreme Court clarified, first, the evidentiary threshold…