On 19 August 2026, the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (the “Ukraine Ordinance”; the following citations in each case refer to the Ukraine Ordinance), thereby completing the implementation of the EU’s 20th sanctions package against Russia (see press release here). This final step follows the initial implementation step taken on 22 May 2026, when the Swiss Federal Council updated several Annexes to the Ukraine Ordinance as a consequence of the same package and, in particular, extended various sanctions lists (see our blog here). The revision announced on 19 August 2026 did not include any amendments to the Ordinance on Measures against Belarus, which was last updated on 22 May 2026.
The latest revisions update Switzerland’s goods, trade and financial restrictions, ultimately introduce a new anti-circumvention measure as well as further shipping- and LNG-related measures, and strengthen the framework for legal protection against Russian countermeasures. Overall, the amendments bring the Swiss regime largely in line with the latest changes to Regulations (EU) No 833/2014 and (EU) No 269/2014 of 23 April 2026 (see blog post here), while maintaining Switzerland-specific exceptions, licensing grounds and implementation timelines.
Most amendments introduced by the revised Ukraine Ordinance entered into force on 20 August 2026, with staggered effective dates for certain shipping- and LNG-related provisions, the extension of the services ban to managed security services, and certain Ukraine-related trade measures.
Key Amendments Regarding Russia
Updated Energy and Trade Restrictions
- Changes to goods restrictions and respective Annexes The existing ban on goods for industrial strengthening has been expanded (Annex 23) and a new Annex 23b has been introduced (Art. 11a para. 1ter). As of 1 September 2026, certain authorization requirements will no longer apply with respect to Ukraine (Arts. 2a, 4, 5, 9a and 9b), originally introduced for neutrality reasons.
- Restrictions on tanker transfers and anti-circumvention safeguards The most recent changes further prohibit the sale of tankers to Russia (Art. 12c para. 1), while introducing new safeguards designed to prevent sanctions circumvention. Contracts for the sale of covered tankers to third countries must now include contractual “no-Russia” clauses preventing subsequent transfers to Russia and such sales (or “other transfers of ownership”) must be notified to SECO (Art. 12c paras. 2 and 3).
- New LNG-related infrastructure and maritime transport restrictions Newly introduced measures prohibit services relating to icebreakers (Art. 12e para. 1), LNG tankers (Art. 12e para. 2) and LNG terminals (Art. 12h) connected with Russia. Some of these restrictions will not take effect until 1 January 2027 (Art. 12e para. 2 let. d and e, Art. 12h and Annex 24).
Anti-Circumvention Measures Targeting Third Countries
- Implementation of EU anti-circumvention tool Switzerland has, at last, also implemented the EU’s anti-circumvention mechanism designed to prevent sensitive goods from being exported to third countries and subsequently re-exported to Russia. The measure currently applies to the Kyrgyz Republic and prohibits the sale, export, transit and transport of machining centers for working metal and machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus (Art. 14h para. 1 and Annex 38). The restrictions also cover related services, financing, technical assistance, as well as the sale of intellectual property rights and trade secrets connected with the relevant goods and technologies (Art. 14h paras. 2 and 3).
Financial and Crypto‑Related Restrictions
- Extension of loan restrictions to credit facilities The revised Ukraine Ordinance now expressly, to avoid any misunderstanding, covers both loans and credits (Art. 19), meaning that the granting of such financing to the relevant recipients (Art. 18 paras. 1 and 3) remains prohibited. The existing exceptions, combined with notification requirements (if applicable), remain in force (Art. 19 para. 3 to 6).
- Restrictions on crypto-asset transfers and Russian payment alternatives The prohibition on transactions involving Russian crypto-assets has been extended to central bank digital currencies, such as the digital ruble. The Ukraine Ordinance further prohibits the support for the development of such instruments (Art. 20a and Annex 13a). Furthermore, the use of Russian platforms for the transfer and exchange of crypto-assets is banned (Art. 20b).
- Additional exceptions from the transaction ban with certain banks Additional exceptions have, inter alia, been introduced for transactions relating to the payment of reasonable legal fees and related expenses, as well as for certain needs of state-funded organizations relevant to Switzerland’s cultural policy in Russia (Art. 27 para. 2 let. a).
Other Measures
- Extension of software and services ban to managed security services With effect from 21 September 2026, the software and services ban will be extended to managed security services (Art. 28e para. 1 let. i). This extension will be relevant for upcoming notifications to SECO under the group exception (cf. Art. 28e para. 8 let. a), which will be due next time by 31 January 2027 (Art. 28e para. 9).
- Extension of the ban on certain Russian government funding In addition, the existing ban on accepting grants originating from the Russian government or state-controlled entities has been extended to include NGOs, media service providers, companies in the research and innovation sector, as well as research and educational institutions (Art. 28g para. 2).
- New transaction restrictions to protect Swiss companies The Federal Council has adopted further transaction prohibitions to safeguard intellectual property rights (Art. 28i and Annex 39) and to protect Swiss companies from “certain” (i.e., abusive) Russian court rulings (Art. 28j and Annex 40). Transactions with persons or entities listed in Annex 41 and thus connected to the enforcement of certain Russia-related claims in third countries are restricted (Art. 28k para. 1), whereby certain limited exceptions apply (para. 2).
- Enhanced legal remedies and expanded prohibition on satisfying certain claims New provisions strengthen the Swiss legal framework to protect Swiss natural and legal persons as well as natural persons domiciled in Switzerland against certain Russian court proceedings by allowing Swiss persons and companies to seek orders before Swiss courts in support of agreed arbitration clauses (Art. 29d paras. 1bis and 1ter). The prohibition on satisfying certain claims (Art. 30) has been expanded to cover certain third-country persons and entities involved in prohibited supplies or in sanctions circumvention (Art. 30 para. 1 let. d).
Looking Ahead: Alignment Achieved, Timing Challenges Remain
With the latest implementation, Switzerland has once again largely closed the alignment gap with the EU regime created by the EU’s 20th sanctions package, while maintaining its own regulatory framework. As pointed out, certain measures introduced on 19 August 2026 only enter into force from September 2026 onwards or even at the beginning of 2027. It is interesting to note that the Federal Council’s felt compelled to clarify in its respective press release that latest measures would be implemented “in line with previous practice”. Such statement could be interpreted as an attempt to address concerns that Switzerland might be considering a substantive departure from the EU approach. In light of this unambiguous remark, the authors expect that Switzerland will continue to implement future EU sanctions largely in substance, while maintaining a distinct “Swiss finish”.
Nevertheless, the recurring implementation delays remain a practical compliance challenge. Notably, by the time Switzerland implemented the 20th package in substance, the EU had already adopted its 21st sanctions package amidst rumors of a 22nd sanctions package. Companies operating in or from Switzerland should therefore continue to closely monitor developments in both jurisdictions and regularly update their sanctions compliance frameworks to address periods of regulatory divergence until Switzerland ultimately closes the gap.
