Author

Philippe M. Reich

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On 16 May 2024, SECO published the updated version of its Auslegungshilfe Sanktionsmassnahmen (“interpretation guideline for sanctions measures”; “FAQs”), which includes additional guidance on the following five topics: (i) proof of the non-Russian origin of imported diamonds and diamond products in relation to the prohibition of Art. 14e of the Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (“Ordinance”); (ii) the mandatory format for fulfilling the reporting obligation for…

Having focused on the enforcement of sanctions by Australia and Ukraine in the past weeks, we now turn our attention to the sanctions enforcement trends in Switzerland. What are the recent sanctions enforcement trends in Switzerland? The State Secretariat for Economic Affairs (“SECO”) is responsible for the enforcement of violations under the Federal Act on the Implementation of International Sanctions (“Embargo Act”; accessible here) and thus also for violations under the Ordinance on Measures in connection…

On 25 January 2023, Switzerland implemented the EU’s 9th sanctions package adopted on 16 December 2022, and is now again by and large in alignment with EU sanctions against Russia. Switzerland thereby also introduced new measures, consisting, among others, of the following: Extension of the scope of prohibitions: The sale, transport and transit of petroleum products of customs tariff number 2710 obtained from crude oil from or originating in the Russian Federation imported into Bulgaria…

In the last month of 2022, Switzerland implemented further EU sanctions measures against the Russian Federation. In summary, Switzerland adopted the following amendments: On 8 December 2022, the Federal Department of Economic Affairs, Education and Research (EAER) amended Annexes 7, 8, 18, and 28 of the Ordinance on Measures connected with the Situation in Ukraine (the “Ordinance“).On 16 December 2022, the Federal Council amended the measures on trade, brokering and transport of crude oil and…