In the last month of 2022, Switzerland implemented further EU sanctions measures against the Russian Federation.
In summary, Switzerland adopted the following amendments:
- On 8 December 2022, the Federal Department of Economic Affairs, Education and Research (EAER) amended Annexes 7, 8, 18, and 28 of the Ordinance on Measures connected with the Situation in Ukraine (the “Ordinance“).
- On 16 December 2022, the Federal Council amended the measures on trade, brokering and transport of crude oil and petroleum products in Articles 12b and 35 of the Ordinance.
- Lastly, on 21 December 2022, the EAER added additional designated parties to Annex 8 of the Ordinance.
The amendments entered into force on 8 December, 16 December, and 21 December 2022 at 6 pm respectively.
These amendments were made in addition to the existing Swiss sanctions against the Russian Federation. As of 25 November 2022, Switzerland has blocked CHF 7.5 billion in financial assets and 15 properties of sanctioned natural persons, companies and organisations in Switzerland. Also, a total of 123 persons or institutions reported 7,548 business relationships worth CHF 46.1 billion to SECO. In connection with the Swiss sanctions against Belarus, 28 notifications were received by SECO, covering 294 business relationships worth CHF 0.4 billion.
Further details on the recent amendments may be found below.
Prohibited Goods
On 8 December 2022, the EAER amended the list of prohibited goods in Annex 7 of the Ordinance. These goods, according to Article 14 of the Ordinance, may not be sold, delivered, exported, and transmitted to individuals or entities within the restricted territories. The list of prohibited goods now includes among others extensive machinery, iron and steel parts, as well as chemicals.
Luxury Goods
On 8 December 2022, the EAER amended Annex 18 of the Ordinance listing luxury goods. Pursuant to Article 14b of the Ordinance, these goods may not be sold, delivered, exported, and transmitted to individuals or entities within the Russian Federation.
Crude Oil and Petroleum Products
On 8 and 16 December 2022, the Federal Council decided to adopt the EU measures on a price cap on crude oil and petroleum products in full. In view of the ongoing military aggression against Ukraine and Russia’s further destabilisation of the country, the had EU adopted new provisions regarding a price cap on crude oil and petroleum products from Russia (oil price cap) on 3 December 2022. Thus, the EU had extended the existing ban on the transport of these goods, which applies when they are sold at a price above the cap, to trade and brokering as well.
The provisions applicable in Switzerland with regard to this price cap now correspond to those of the EU. They are set out in Articles 12b and 35 of the Ordinance. Furthermore, these measures are now also applicable to crude petroleum oils or oils obtained from bituminous minerals (see respective list in Annex 28 of the Ordinance).
Designated Parties
On 8 December 2022, the EAER added two Iranian individuals and two Iranian organisations to Annex 8, thus subjecting them to financial sanctions and travel restrictions. These two Iranian individuals and entities had already been designated by the EU on 14 November 2022 for their role in the development and supply of unmanned aerial vehicles to the Russian Federation.
On 21 December 2022, the EAER placed a further four individuals and four entities from Iran on the designated parties list in Annex 8, thus subjecting them to financial sanctions and travel restrictions. These individuals and entities were involved in Iran’s military support for Russia and its supply of drones to Russia. The EAER also placed 141 Russian individuals and 49 Russian entities on the designated parties list in Annex 8. This is due to their involvement in missile and drone attacks on the civilian population and on civilian objects and infrastructure and the illegal annexation of the Ukrainian regions of Donetsk, Luhansk, Zaporizhzhya and Kherson. They consist of members of the State Duma, ministers, individuals and companies responsible for propaganda, members of the military and various branches of the Russian armed forces. The amendments to the designated parties list follow the additions made by the EU on 12 December 2022 and 16 December 2022.
The substantive changes of the 9th EU sanctions package have not been implemented yet by Switzerland. A respective proposal is expected to be made to the Federal Council in the course of January 2023.
The latest version of the Ordinance is here.
The updated list of sanctioned individuals and entities is here.
