On 25 February 2026, the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (the “Ukraine Ordinance”), thereby completing the implementation of the EU’s 19th sanctions package against Russia (see press release here). This final step follows the initial implementation step taken on 12 December 2025, when the Swiss Federal Council updated several annexes to the Ukraine Ordinance as a consequence of the same package (see…
From 14 May 2025, certain additional businesses are now subject to mandatory sanctions reporting obligations as changes to the definition of “relevant firms” for financial sanctions reporting purposes come into force. Consequently, High Value Dealers (HVDs), Art Market Participants (AMPs), Letting Agents and Insolvency Practitioners are now legally required to report to OFSI whether they have knowledge or reasonable cause to suspect the presence of sanctioned parties, or suspected financial sanctions breaches. These obligations were…
On 24 April 2025, the UK government published the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 25 April 2025 (“Amending Regulations”). These new regulations amend the Syria (Sanctions) (EU Exit) Regulations 2019 to partially suspend a number of significant sanctions that have been in place for over a decade to reflect the developments to the political situation in Syria following the fall of the Assad regime in December 2024. The UK…
On 23 April 2025, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 24 April 2025. These new regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce additional trade restrictions, focusing on export and import prohibitions, technology, and software transfers. We have set out summaries of the key new measures below. Sectoral Software The amending regulations introduce prohibitions on making available and transferring “sectoral software” to…