On 22 May 2026, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this step, Switzerland has partially implemented the measures adopted by the EU under its 20th sanctions package. The corresponding amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) and the Ordinance on Measures against Belarus (“Belarus Ordinance”) entered into force on 22 May 2026.
Following established procedure, the Federal Department of Economic Affairs, Education and Research (EAER) has hereby exercised its authority to implement new listings. However, the substantive measures contained in the 20th sanctions package have yet to be considered and adopted by the Federal Council. While the EU adopted its 20th sanctions package on 23 April 2026 (see our blog here), Switzerland continues to exhibit a widening time gap between EU sanctions adoption and Swiss sanctions implementation. We currently expect the substantive implementation of the 20th sanctions package not to occur before the summer break.
Under the newly adopted listings, 115 additional individuals and entities have been designated under Annex 8 of the Ukraine Ordinance, becoming subject to asset freezes and prohibitions on the provision of funds or economic resources, with individuals also facing entry and transit bans in Switzerland. The listings predominantly target actors linked to Russia’s military‑industrial complex and energy sector, as well as persons associated with the deportation and indoctrination of Ukrainian children.
Notably, Switzerland has refrained from formally listing seven companies located in third countries. This is not the first instance in which Switzerland has omitted certain third‑country actors when implementing EU listings and is particularly noticeable with regard to the absence of certain Chinese entities, suggesting that this approach may again reflect a deliberate political choice on the part of Switzerland.
Alongside these designations, Switzerland has expanded a range of trade and financial restrictions targeting further individuals and entities. In the trade sphere, 60 companies, here also including entities based in third countries, are now subject to tighter export controls measures designed to restrict access to critical goods (Annex 2 of the Ukraine Ordinance). Efforts to curb the activities of Russia’s shadow fleet have also been reinforced, with 46 vessels being newly designated (Annex 33 of the Ukraine Ordinance), coupled with transaction bans targeting two Russian ports (Murmansk and Tuapse) and one Indonesian port involved in oil shipments (Annex 15c of the Ukraine Ordinance). In the financial sector, comprehensive transaction bans have been extended to 20 Russian banks (Annexes 14 and 14a of the Ukraine Ordinance) and seven third‑country intermediaries (Annex 15b of the Ukraine Ordinance). Finally, as of 26 May 2026, transactions involving the Russian cryptocurrency RUBx and the digital rouble are prohibited under the relevant restrictions on crypto‑asset transactions (Annex 13a of the Ukraine Ordinance).
Similar listings have also been implemented under the Belarus Ordinance.
This two–tiered approach, whereby Switzerland first adopts the EU’s listings while deferring the broader substantive measures, continues to characterize Swiss implementation practice. As confirmed in the Federal Council’s communication, the more far–reaching measures contained in the EU’s 20th sanctions package – particularly in the financial, energy and trade sectors – remain under consideration. While their eventual adoption is expected, further delays of several weeks, if not months, are likely, requiring Swiss operators, for the time being, to continue navigating an increasingly fragmented Russia and Belarus sanctions landscape.
