On 12 October 2022, the Swiss Department of Economic Affairs, Education and Research (the “EAER”) amended Annex 6 and Annex 8 of the Swiss Ordinance on Measures connected with the Situation in Ukraine (the “Ordinance”). The amended annexes entered into force on 12 October 2022 at 18:00 CET. There were no substantive amendments to the Ordinance yet, but consultation has been initiated, leading to a proposal to Swiss government.
The modification introduced 30 individuals and seven organisations and entities to Annex 8 and thus subjects them to an asset and economic resource freeze pursuant to Article 15 of the Ordinance. These individuals predominately promoted the so-called “referenda” organized by Russia in the respective Ukrainian regions at the end September. Switzerland is now fully in line with the EU latest designated parties list in Regulation (EU) 260/2014 as was amended by the eighth EU sanctions package via Council Implementing Regulation (EU) 2022/1906 of 6 October 2022.
Furthermore, the modification included the following territories to Annex 6:
- Areas of Kherson Oblast of Ukraine not controlled by the Ukrainian government;
- Areas of Zaporizhzhia Oblast of Ukraine not controlled by the Ukrainian government.
These territories are now subject to the restrictions on importation and exportation of goods from and to the designated territories (Article 13 and 14 of the Ordinance) and the prohibition on financings, investments and services in the designated territories (Article 25 of the Ordinance).
The EAER also informed the Federal Council of its intention to review and potentially adopt substantive measures contained in the eighth EU sanctions package. We anticipate implementation of these substantive measures in the coming weeks.
The latest version of the Ordinance is here.
The updated list of sanctioned individuals and entities is here.