On 25 February 2026, the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (the “Ukraine Ordinance”), thereby completing the implementation of the EU’s 19th sanctions package against Russia (see press release here). This final step follows the initial implementation step taken on 12 December 2025, when the Swiss Federal Council updated several annexes to the Ukraine Ordinance as a consequence of the same package (see our blog here). In addition, the oil price cap for Russian crude oil destined for third countries was lowered from USD 47.60 to USD 44.10 as of 1 February 2026.
The latest revisions, which are far‑reaching in scope, significantly expand existing (and introduce new) restrictions relating to Russian energy supplies, financial services, high‑tech and professional services, Special Economic Zones (“SEZ”), and a range of industrial and luxury goods. Overall, the measures closely align Switzerland with the latest amendments to Regulations (EU) No 833/2014 and (EU) No 269/2014 (see blog post here), while incorporating Switzerland‑specific exceptions, licensing grounds and transition periods.
On 25 February 2026, the Swiss Federal Council also announced to join the EU sanctions imposed against Belarus in October 2025 by amending the Ordinance on Measures against Belarus (the “Belarus Ordinance”), thereby synchronizing Switzerland’s sanctions against Belarus largely with Regulation (EU) No 765/2006.
Moreover, on 26 February 2026, the Swiss Federal Department of Economic Affairs, Education and Research (EAER) updated the document entitled “Interpretative Guidance on Sanctions Measures,” (Auslegungshilfe Sanktionsmassnahmen), the primary source of interpretation guidelines concerning Switzerland’s Russia sanctions. The updates to the document relate in particular to the interpretation of financial restrictions.
Most amendments introduced by the revised Ukraine Ordinance and Belarus Ordinance entered into force on 26 February 2026, but with staggered effective dates for the provisions of the Ukraine Ordinance concerning restricted services, LNG bans, and SEZ‑related prohibitions.
Key Amendments regarding Russia
Energy‑Related Restrictions
- Clarification regarding the ban on purchase and import of petroleum products from third countries (Art. 12abis of the Ukraine Ordinance)
With regards to this previously existing ban on crude oil derivatives and petroleum products, the Swiss Federal Council has clarified that the prohibition to purchase such products produced in third countries from Russian‑origin crude applies when Switzerland is the place of destination (para. 1).
- Comprehensive ban on Russian LNG (Art. 12g of the Ukraine Ordinance)
Switzerland had already previously introduced a ban on the purchase, import, etc. of liquefied natural gas (“LNG”) from or originating from the Russian Federation via terminals in the EU that are not connected to the natural gas grid (Art. 12e of the Ukraine Ordinance). The Ukraine Ordinance now prohibits all purchases, imports, transits and transports of LNG (classified under HS Code 2711 11) (as well as ancillary services relating to such activities) from or originating from Russia (Art. 12g of the Ukraine Ordinance) as of 25 April 2026 (with a transition period for pre-existing long-term supply contracts). This reflects the EU’s LNG restrictions under Art. 3ra of Regulation (EU) 833/2014.
Updated Trade Restrictions
Multiple Annexes of the Ukraine Ordinance covering goods subject to trade restrictions have been amended (and, in parts, significantly extended):
- Annex 1 of the Ukraine Ordinance (goods linked to military and technological enhancement) has been expanded to include, inter alia, metals used in the construction of weapon systems and products used in the manufacture of fuels.
- Annex 18 of the Ukraine Ordinance (restricted luxury goods) now covers additional items such as refrigerators; at the same time, certain goods – including smartphones, other electronic devices and specific vehicle types – have been removed from the list.
- Annex 23 of the Ukraine Ordinance (goods for industrial strengthening) has been broadened to include, inter alia, salts and ores, rubber articles, tubes and tires, as well as millstones and construction materials.
- In addition to these export, etc. restrictions, new purchase and import bans have been introduced for goods of economic significance to Russia under Annex 20 of the Ukraine Ordinance, including acyclic hydrocarbons.
Financial and Crypto‑Related Restrictions
- Ban on providing crypto‑services to Russian persons (Art. 20 of the Ukraine Ordinance)
The prohibitions on crypto‑services have been expanded and clarified. Revised Art. 20 para. 2 of the Ukraine Ordinance now prohibits the professional provision, directly or indirectly, of crypto‑asset services, payment services (including the issuance of payment instruments, payment initiation services and the acceptance and settlement of payment transactions) and the issuance of e‑money to Russian nationals, persons resident in the Russian Federation and entities established in the Russian Federation. These restrictions, however, only apply if they are provided commercially (gewerbsmässig; see Art. 20 para. 2 of the Ukraine Ordinance). In addition, under the revised Art. 20 para. 2bis of the Ukraine Ordinance, Russian nationals and Russia‑resident individuals are prohibited from acquiring ownership in, exercising control over, or assuming management or governing functions in Swiss‑ or EEA‑based providers of crypto‑wallet, crypto‑account or crypto‑custody services. Certain exceptions and licensing grounds exist (let. a). All these measures replicate the EU’s focus on non‑bank digital asset channels (see Art. 5b of Regulation [EU] 833/2014).
- Prohibition on transactions involving certain crypto‑assets (Art. 20a of the Ukraine Ordinance)
A new ban has been introduced on the direct or indirect involvement in transactions concerning crypto‑assets, as listed in the newly added Annex 13a of the Ukraine Ordinance, banning transactions involving certain the ruble-backed cryptocurrency stablecoin A7A5.
- Extension of the transaction ban regarding comparable and successor entities (Art. 24c para. 1 let. c of the Ukraine Ordinance)
The existing Art. 24c of the Ukraine Ordinance, which prohibits transactions with entities listed in Annex 15b of the Ukraine Ordinance, has been extended to include banks and organizations operating as “comparable or successor entities” to those listed in Annex 15b of the Ukraine Ordinance.
- Expansion of exceptions applying to prohibitions on transactions with listed banks (Art. 27 para. 2 let. a of the Ukraine Ordinance)
New exceptions have been introduced to the existing ban on transactions with banks listed in Annex 14 of the Ukraine Ordinance, now allowing transactions necessary for the purchase, etc. of non‑restricted pharmaceuticals, medical devices, agricultural products and foodstuffs.
- Restrictions on financial messaging systems (Art. 27a of the Ukraine Ordinance)
The existing prohibition applicable to the Russian financial messaging and payment systems has been expanded. Whereas the initial measure was limited to direct connections with the financial messaging system of the Central Bank of the Russian Federation, or equivalent systems, the scope has now been broadened to cover connections to any systems operated by the Central Bank of the Russian Federation, as well as payment messaging systems provided by other legal persons established under Russian law. This explicitly includes the System for Fast Payments and the Mir card payment system (cf. Art. 27a para. 1 of the Ukraine Ordinance), thereby further reinforcing the financial decoupling of the Russian financial infrastructure.
New Restrictions on Special Economic Zones (Art. 28bbis of the Ukraine Ordinance)
Under this new provision, Switzerland has introduced comprehensive bans on a variety of transactional interactions with entities domiciled, etc. in so-called Russian special economic, innovation, and preferential zones, as listed in a new Annex 14b of the Ukraine Ordinance. Mentioned Annex differentiates between two categories of such SEZ, whereby the first category – which triggers the more restrictive prohibitions – currently only includes two SEZ. Prohibited activities under Art. 28bbis of the Ukraine Ordinance include: (i) establishing, expanding and (even) maintaining ownership interests, (ii) creating or retaining joint ventures, branches or representative offices, (iii) concluding or maintaining contracts related to goods, services, IP rights, or trades secrets; (iv) directly or indirectly providing loans, credit, financing or investment services. These newly introduced restrictions align with the EU’s focused prohibitions targeting such zones in Art. 5ah of Regulation (EU) 833/2014. Limited exceptions apply, notably for humanitarian and environmental purposes, certain energy‑related activities, and specific purchases of non‑Russian‑origin oil transported via Russian ports. SECO may also authorize exceptions to these restrictions, if it is necessary for the withdrawal of investments from or the termination of business activities in the Russian Federation (Art. 30csexies of the Ukraine Ordinance).
Broadened Prohibitions on Services and Software (Art. 28e of the Ukraine Ordinance)
The revised Ukraine Ordinance substantially reorganizes and expands restrictions on services and software (the so-called “software and services ban”), reflecting the EU’s objective of limiting Russia’s access to high‑value intellectual input, technical capacity, and computational resources. Newly prohibited services include urban planning, scientific and technical consulting services related to engineering services, technical testing and analysis services, commercial space-based services related to Earth observation and satellite navigation, artificial intelligence services related to access to models or platforms for training, fine-tuning and inference, high-performance computing services and tourism-related services (cf. Art. 28e paras. 1 and 3 of the Ukraine Ordinance, noting that some of these service restrictions will enter into force on 27 March 2026) In addition, any other services not expressly listed in Art. 28e paras. 1 and 3 of the Ukraine Ordinance now require authorization if provided to the Russian Government (see Art. 28e para. 7 of the Ukraine Ordinance, in alignment with Art. 5n[4] of Regulation (EU) 833/2014). Restricted services provided under the intra-group or the humanitarian exceptions must be notified to SECO on a semi-annual basis, whereby the next notification is due as of 31 July 2026 for the period starting 1 February 2026 (Art. 28e paras. 8-9 of the Ukraine Ordinance). In light of the extensive amendment to Art. 28e of the Ukraine Ordinance, an updated SECO template notification form will be necessary.
Ban on Reinsurance of Russian Ships and Aircrafts (Art. 28h of the Ukraine Ordinance)
The new provision introduces a five‑year ban (starting with the sale or any form of leasing of ships or aircrafts) on entering into, underwriting or otherwise providing insurance‑related contracts or arrangements that assume, transfer or assign risks relating to the insurance coverage of ships or aircraft that were operated by the Government of the Russian Federation or by entities established in the Russian Federation. The respective ban starts with the sale or any form of leasing of such ships or aircrafts. This new restriction further limits Russia’s ability to maintain its maritime and aviation fleets through alternative insurance markets.
Key Amendments regarding Belarus
The amendments to the Belarus Ordinance further expand Swiss sanctions against Belarus, with the explicit objective of aligning the Belarus regime more closely with that applicable to Russia to strengthen the impact of both these regimes and prevent circumvention. The revised Belarus Ordinance includes the introduction of a mirroring provision of the above-discussed crypto‑related prohibitions (Art. 18 of the Belarus Ordinance) and a similarly extensive expansion of the restrictions on services and software (Art. 24b of the Belarus Ordinance). Similar licensing grounds applicable to the transaction ban on certain banks, such as for transactions relating to the purchase of non‑restricted pharmaceuticals, medical devices, agricultural products and foodstuffs, were introduced under Art. 23 para. 2 of the Belarus Ordinance.
In addition, further licensing grounds have been introduced for the transaction ban concerning certain banks, as well as for the provision of restricted services and software in the context of divestments, under Art. 27b and 27bbis of the Belarus Ordinance. Finally, as is the case under the revised Ukraine Ordinance, several luxury items previously listed under Annex 21 of the Belarus Ordinance are no longer subject to export restrictions and Annex 22 of the Belarus Ordinance setting out import restrictions on goods of economic significance now also includes acyclic hydrocarbons.
Looking Ahead: Compliance Implications and Anticipated Developments
With the implementation of the EU’s 19th sanctions package, Switzerland has finally closed the alignment gap with the EU sanctions against Russia since October 2025, reaffirming its commitment to broadly mirror EU sanctions policy while preserving its own regulatory framework. That said, the extended delay in implementation once again created legal uncertainty for Swiss and EU market participants operating across jurisdictions, a pattern that is likely to repeat itself not only in the near term as the EU moves closer to adopting its 20th sanctions package, but also in future when further measures will be adopted. This development comes against the backdrop of the fourth anniversary of Russia’s invasion of Ukraine, with recent peace talks hosted in Geneva having failed to yield tangible progress, underscoring that the sanctions regime is set to remain a defining feature of the European regulatory landscape for the foreseeable future. Companies operating in or from Switzerland should therefore continue to conduct comprehensive sanctions risk assessments and regularly update their internal controls, as the cumulative effect of successive sanctions packages is materially increasing compliance complexity and exposure.
