On 6 November 2024, the Swiss Federal Council announced the implementation of new, albeit limited, sanctions against the Islamic Republic of Iran, which entered into force on 7 November 2024. This update to the Ordinance on Measures against the Islamic Republic of Iran (“Iran Ordinance”) primarily targets goods and technology related to unmanned aircrafts, along with an expansion of the list of designated parties involved in this sector.
Reorganization and extension of restrictions on goods and technology related to unmanned aircrafts
Art. 2a of the Iran Ordinance prohibits the sale, supply, export and transit of goods and technology for unmanned aircrafts to Iranian persons or entities or for use in Iran, the provision of any related services and of financing, investments, participations and joint ventures in connection therewith. It further also prohibits the procurement, import, transit, transportation and brokering of such goods and technology from Iran.
Annex 1a of the Iran Ordinance lists the goods and technology subject to these restrictive measures and has been substantially expanded with this latest round of new measures, now including:
- Definitions for all key items, such as “satellite navigation system” and “unmanned aircraft”.
- New and expanded categories for goods such as “general electronics” and “aviation electronics and navigation”.
- A number of additional goods such as additional remote control devices for unmanned aerial vehicles, telecommunications apparatus, equipment or installations for aircrafts as well as antennas and antenna reflectors for aircrafts.
Expansion of designated persons list
Natural persons, companies, and entities listed in Annexes 5-7 of the Iran Ordinance are subject to asset freezes, travel bans, and restrictions concerning the fulfilment of certain claims. Individuals included in Annex 6a are also affected by these restrictions. However, exemptions may be granted under specific circumstances. For instance, travel for humanitarian purposes or the provision of funds necessary for humanitarian activities in Iran by public bodies or organizations receiving federal support may qualify for such exemptions.
The latest update of the Iran Ordinance added 13 natural persons and 11 entities to the aforementioned Annex 6a, including Iran’s Minister of Defence, the military attaché of the Iranian Embassy in Russia, as well as various divisions of the Islamic Revolutionary Guard Corps and airlines, for their involvement in the transfer of Iran’s unmanned aerial vehicles and other weapons to Russia or to Iranian-aligned armed groups in Syria, Lebanon, Iraq and the Occupied Palestinian Territories, thereby contributing to the war of aggression against Ukraine and undermining the peace and security in the Middle East and the Red Sea region.
This listing is in line with the latest EU amendment, dated 14 October 2024, to Annex III to Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region.
Conclusion
After long, Switzerland has again amended the substance of the Iran Ordinance to align with the EU. This is due to Iran’s role in the supply of drones, etc. to the wars raging in the Ukraine and other regions in the world.
