On 12 December 2025, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this expansion, Switzerland has partially implemented the measures adopted by the EU under its 19th sanctions package. The updated Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”; see link here) entered into force on 13 December 2025.
Following established procedure, the Federal Department of Economic Affairs, Education and Research (EAER) has (already) exercised its authority to implement these new listings. However, the substantive measures contained in the 19th sanctions package have yet to be considered and adopted by the Federal Council, save for some minor amendments to the Ukraine Ordinance that have already been introduced, as set out below. This reflects the considerable delays that can now be seen in the implementation of recent EU Russia and Belarus sanctions: While the EU introduced its 19th sanctions package on 23 October 2025 (see our blog here), Switzerland’s last significant update of its Russia sanctions – the implementation of the EU’s 18th sanctions package – occurred almost two months ago on 29 October 2025 (see our previous blog here). This demonstrates a widening gap between Swiss and EU sanctions implementation. According to information obtained from the Swiss authorities, substantive implementation of the 19th sanctions package is unlikely to occur before February 2026, leaving Swiss companies to navigate increasingly divergent sanction regimes.
By 13 December 2025, an additional 22 natural persons and 42 entities – connected to Russia’s military-industrial complex, energy sector and the management of the shadow fleet – are now subject to asset freezes and the related financial restrictions included in the Ukraine Ordinance. The measures also extend to several Chinese trading companies and a Chinese refinery (see Article 15 in connection with the listings in Annex 8 of the Ukraine Ordinance). In addition, more than 100 vessels, primarily tankers forming part of Russia’s shadow fleet, have been listed in Annex 33 of the Ukraine Ordinance and now face comprehensive bans on purchases, sales and related services. These vessels are suspected to be specifically deployed to circumvent price caps on Russian crude oil and petroleum products.
Additional entities, including Chinese companies, were added to Annex 2 of the Ukraine Ordinance, which lists sanctioned end users of dual-use goods and items contributing to Russia’s defence and security sector (see Articles 4 and 5 of the Ukraine Ordinance). Five Russian banks are newly affected by the transaction ban set out in Article 27 of the Ukraine Ordinance, and four Russian bank branches in Belarus and Kazakhstan are sanctioned due to their use of specialised messaging services for payment transactions (Article 27a of the Ukraine Ordinance).
In addition to these new listings in the various Annexes of the Ukraine Ordinance, certain substantive amendments were introduced: The title of Article 24c is now “Prohibition of transactions with certain banks and organisations that undermine the purpose of the sanctions”, reflecting the revised Article 5ad of Regulation (EU) 833/2014 under the 19th sanctions package. This transaction ban now also encompasses financial institutions and oil trading companies in third countries (i.e., Tajikistan, Kyrgyzstan, the United Arab Emirates and Hong Kong), which are involved in circumventing sanctions. Therefore, Article 24c no longer focuses only on entities involved in crypto assets services; its scope has been expanded to serve a broader anti-circumvention cause. Furthermore, in the context of divestments, several deadlines were extended by another year: The State Secretariat for Economic Affairs (SECO) may now grant exemptions to withdraw investments from Russia until the end of 2026.
Finally, Switzerland also amended listings under the Ordinance on Measures against Belarus. Five new persons are now subject to the asset freeze due to touchpoints with the Belarusian military-industrial complex.
We will provide a further report on the next and final implementation steps taken by the Swiss government.
