Swiss government significantly expands sanctions against Iran

On 12 December 2025, the Swiss Federal Council announced its decision to significantly expand Switzerland’s sanctions against Iran (see press release here) following a comprehensive revision of the Ordinance on Measures against the Islamic Republic of Iran (“Iran Ordinance”; see link here). With this revision, the Swiss government implemented several recent UN Security Council resolutions, effectively restoring Switzerland’s sanctions regime to the level that existed before 2016.

The revision also introduces additional measures relating to raw materials. Its primary goal is to prevent Switzerland from being used to circumvent EU sanctions against Iran and to enhance legal certainty for Swiss companies operating internationally.

The revised Iran Ordinance entered into force on 12 December 2025.

1. Background

Following the entry into force in 2015 of the Iran nuclear deal, also known as the Joint Comprehensive Plan of Action (JCPOA), Switzerland significantly eased its Iran sanctions (which since 2011 had been based on various UN Security Council resolutions and partially aligned with EU measures) in January 2016, in accordance with UN Security Council Resolution 2231 (2015) and corresponding EU decisions. As part of this process, the Iran Ordinance was comprehensively revised on 17 January 2016 and has since only been subject to minor updates, primarily relating to new listings and humanitarian exceptions.

While the United States withdrew from the JCPOA in 2018, France, Germany and the United Kingdom formally triggered the JCPOA’s “snapback” mechanism on 28 August 2025 after unsuccessful UN negotiations in summer 2025 to extend the JCPOA framework, citing Iran’s continued noncompliance with its nuclear-related commitments (see blog post here). As a result of the snapback and the failure to reach an agreement with Iran, all UN sanctions previously lifted under the JCPOA were reinstated, thereby becoming mandatory for Switzerland as well. Accordingly, on 20 October 2025, the competent Federal Department of Economic Affairs, Education and Research adopted the listings under the reinstated UN sanctions. In parallel, the Federal Council announced its intention to consider the substantive implementation of the reinstated measures and the additional EU measures adopted since then – a process that has now been completed.

2. New measures

Trade restrictions

• Restrictions on dual-use items
  • Under Art. 2 of the Iran Ordinance, the sale, supply, export and transit of dual-use goods, technology and software, as listed in Annex 1 of the Iran Ordinance, to Iranian persons or organizations (as defined in Art. 1 let. f of the Iran Ordinance) or for use in Iran are prohibited. Similar restrictions apply to the provision of ancillary services and investments (para. 2). Certain exceptions and exemptions apply (paras. 4 and 5).The procurement, import, transit, transport and brokering of items listed in Annex 1 of the Iran Ordinance from Iran are prohibited (Art. 2 para. 3 of the Iran Ordinance). Again, certain exceptions and exemptions apply (paras. 4 and 5).Annex 1 of the Iran Ordinance is split into three sections. Section A references the dual-use items listed in Annex 2 of the Goods Control Ordinance as well as nuclear materials as defined in Art. 1 para. 1 of the Nuclear Energy Ordinance. Section B lists “further goods,” including, for example, “nuclear materials, facilities, and equipment,” “sensors and lasers” and “aviation technologies,” which for the purposes of this restriction are considered dual-use items. Finally, Section C lists technologies and software required for the development, production or use of the items listed in both Annex 1 and Annex 2 of the Iran Ordinance. 
• Art. 3 of the Iran Ordinance introduces a new category of “particular dual-use items” that are listed in Annex 2 of the Iran Ordinance. In contrast to Annex 1 items and the respective restrictions in Art. 2 of the Iran Ordinance, Art. 3 provides that the sale, supply, export and transit of dual-use goods, technology and software listed in Annex 2 of the Iran Ordinance to Iranian persons or organizations or for use in Iran are not prohibited but subject to prior authorization. The same applies to the provision of ancillary services or related investments (Art. 3 para. 1 let. b of the Iran Ordinance). SECO will generally grant such authorizations, except in cases where doing so could contribute to certain nuclear or nuclear-weapon-related activities.
• Other export restrictions: New restrictions prohibit the sale, supply, transfer and export as well as, typically, the provision of related ancillary services and/or financing to Iranian persons or organizations or for use in Iran of the following items:
  • Goods and technologies for unmanned aerial vehicles and rockets (Art. 4 and Annex 3 of the Iran Ordinance) – Equal restrictions apply to the procurement, import, transit, transport and brokering of such goods (para. 3). Certain exemptions apply (para. 4).
  • Military equipment and goods for internal repression (Art. 5 and Annex 4 of the Iran Ordinance) – The existing restrictions concerning goods for internal repression have been significantly expanded and now include military equipment as well. The new restrictions apply to military equipment of any kind, including weapons and ammunition, military vehicles and equipment, paramilitary equipment, as well as accessories and spare parts, and goods for internal repression as set out in Annex 4 of the Iran Ordinance. Equal restrictions apply to the procurement, import, transit, transport and brokering of such goods (para. 5). Certain exceptions and exemptions apply (paras. 6 to 9).
  • Equipment, technologies and software for surveillance purposes (Art. 6 and Annex 5 of the Iran Ordinance) –This restriction already existed under the previous version of the Iran Ordinance. However, SECO must now consult the Federal Department of Foreign Affairs when issuing licenses (cf. para. 4).
  • Graphite and raw metals or semi-finished metal products (Art. 7 and Annex 6 of the Iran Ordinance) – The restrictions do not apply to transactions that were contractually agreed before 12 December 2025 and are completed by 13 March 2026 (cf. Art. 33 para. 1 of the Iran Ordinance).
  • Goods for the oil, gas and petrochemical industries in Iran (Art. 8 and Annex 7 of the Iran Ordinance) – The restrictions do not apply to (i) transactions that were contractually agreed before 12 December 2025 and are completed by 13 March 2026, provided they are reported to SECO at least 20 days in advance (cf. Art. 33 para. 2 let. a of the Iran Ordinance); and (ii) investments made in Iran before 12 December 2025 and completed by 13 March 2026, subject to the same 20-day prior notification requirement (Art. 33 para. 2 let. b of the Iran Ordinance).
• Under Art. 9 of the Iran Ordinance, the purchase, import or transport into Switzerland of crude oil or petroleum products listed in Annex 8 of the Iran Ordinance from Iran or originating in Iran is prohibited. Similarly, the provision of any financial support in connection thereto is prohibited (para. 2). Certain exceptions apply (para. 3), and said restrictions do not apply to transactions that were contractually agreed before 12 December 2025 and are completed by 13 March 2026 (Art. 33 para. 3 of the Iran Ordinance).
• Under Art. 10 of the Iran Ordinance, the sale, supply, transfer and export of precious metals and diamonds listed in Annex 9 of the Iran Ordinance, directly or indirectly, to the Iranian government, its public institutions, companies and agencies, as well as to persons or organizations acting on behalf of or at the direction of the Iranian government or persons or organizations controlled by it, are prohibited. Similar restrictions apply to the direct or indirect purchase of such goods (para. 2). Para. 3 prohibits brokering services and financial support in connection with such activities.
• The following activities must be reported to SECO without delay:
  • The delivery, sale or other provision to the Central Bank of Iran of new banknotes and coins denominated in Iranian currency that have been printed or minted in Switzerland (Art. 11 of the Iran Ordinance)
  • The purchase, sale, import and transport of petrochemical products listed in Annex 10 of the Iran Ordinance that are located in Iran, originating in Iran or exported from Iran, as well as any related financial activities (Art. 12 of the Iran Ordinance)
• Finally, the Swiss Export Risk Insurance shall not enter into any new short-, medium- or long-term commitments to cover transactions with Iran, with certain exceptions applying for medical and humanitarian purposes (Art. 13 of the Iran Ordinance).

Financing and participation restrictions

• Financing restrictions – Various new financing restrictions were introduced under Art. 14 of the Iran Ordinance, including the prohibition of the following:
  • Granting loans or credits to Iranian persons or organizations involved in the following:
    • The exploration or extraction of crude oil and natural gas, the refining of fuels, or the liquefaction of natural gas
    • The production of armaments or goods and technologies listed in Annex 1 of the Iran Ordinance
    • The operation of production facilities for petrochemical products listed in Annex 10 of the Iran Ordinance (Art. 14 para. 1 let. a-c of the Iran Ordinance)
  • Acquiring interests in Iranian persons or organizations engaged in the activities described above or establishing joint ventures with them (Art. 14 para. 2 of the Iran Ordinance)
  • Sharing investment costs within an integrated or managed supply chain for the supply or delivery of natural gas indirectly from or to Iran, or directly cooperating for the purpose of investing in liquefied natural gas facilities located in Iran or directly connected to Iranian territory (Art. 14 para. 3 of the Iran Ordinance)
  • Granting loans or credits to Iranian persons or organizations involved in the production of goods and technologies listed in Annex 2 of the Iran Ordinance requires prior authorization from SECO (Art. 14 para. 4 and 5 of the Iran Ordinance).
  • Certain further exceptions and exemptions apply (Art. 14 paras. 6 and 7 of the Iran Ordinance).
• Prohibitions on participations – Iranian persons or organizations are not allowed to acquire interests or establish joint ventures with companies engaged in uranium mining, enrichment or reprocessing, or in developing nuclear materials, controlled goods, technologies or missile systems, as well as to grant or accept loans or credits in connection with such activities (Art. 15 of the Iran Ordinance).

Financial restrictions

• With regard to the asset freeze provisions set out in Art. 16 of the Iran Ordinance, the listings in Annexes 11-14 of the Iran Ordinance were significantly expanded in October 2025, although the core measures remained largely unchanged. The revised provision of 12 December 2025 mainly introduces clearly defined humanitarian exceptions, additional grounds for SECO authorizations (including hardship cases, Swiss interests, diplomatic activities and humanitarian purposes), and a formal requirement for consultation with the FDFA and the FDF.
• According to Arts. 17 and 18 of the Iran Ordinance, SECO may exceptionally authorize the release or provision of frozen funds or economic resources for specific purposes, including fulfilling existing contracts, satisfying claims based on arbitral or judicial decisions, avoiding hardship, paying fees related to ship de-flagging, financing certain activities, humanitarian operations, diplomatic or consular functions, and safeguarding Swiss interests. Applying these exemptions requires prior consultation with the FDFTA and the FDF and, where applicable, notification to the UN Security Council Committee.

Restrictions on money transfers and financial services

• According to Art. 21 of the Iran Ordinance, transfers of funds exceeding CHF 10,000 to or from an Iranian person or organization must be reported in writing to SECO within five business days (para. 1). Transfers above CHF 50,000 require prior SECO authorization, which will be granted provided the transaction does not violate the Iran Ordinance, the Goods Control Act or the War Materiel Act (para. 2). The notification or authorization request must be submitted by the financial intermediary of the issuer of the payment or its beneficiary, or if such intermediary is not based in Switzerland, by the issuer of the payment or its recipient. Again, certain exceptions apply (paras. 4 and 5).
• Under Art. 22 of the Iran Ordinance, banks are prohibited from opening accounts with Iranian banks, establishing correspondent banking relationships, opening a representative office or branch in Iran, creating subsidiaries in Iran, or forming joint ventures with Iranian banks. Conversely, Iranian banks are prohibited from opening a representative office or branch in Switzerland, establishing subsidiaries, or acquiring ownership interests in banks registered under Swiss or EEA law. SECO may grant exceptions to these prohibitions after consultation with the FDFA, the FDF and FINMA.
• Further restrictions have been introduced regarding the following: 
  • Activities around government and government-guaranteed bonds in relation to certain parties (Art. 23 of the Iran Ordinance)
  • Activities around insurance and reinsurance in relation to certain parties (Art. 24 of the Iran Ordinance)

The revised Iran Ordinance entered into force on 12 December 2025.

III. Conclusion

With this comprehensive overhaul, Switzerland has effectively restored its Iran sanctions regime to pre-2016 levels and aligned it with the reinstated UN measures. At the same time, it has introduced additional restrictions aimed at preventing the circumvention of EU sanctions. As outlined above, the new measures significantly expand trade, investment and financing restrictions; impose stricter reporting and licensing requirements; and – clarify the scope of humanitarian exceptions. Notably, the reintroduction of funds transfer controls – previously a major source of operational difficulty – marks a substantial tightening of the framework. Nonetheless, certain divergences from the EU sanctions regime persist. Swiss companies should therefore carefully assess both Swiss and EU measures to ensure full compliance. Businesses with exposure to Iran are strongly encouraged to update their compliance frameworks and seek legal advice where appropriate.