As a first step towards implementing the EU’s 18th sanctions package, the Swiss government amended several annexes to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) on 11 August 2025. The Swiss government also extended the lists of designated persons in the Ordinance on Measures against Belarus (“Belarus Ordinance”) and the Ordinance on Measures against Moldova (“Moldova Ordinance”), following the listings adopted by the EU on 18 and 15 July 2025, respectively (see blog here). The amendments entered into force on 12 August 2025 at 11 pm, except for the amendment to Annex 28 of the Ukraine Ordinance concerning lowering the price cap for crude oil, which will enter into force on 3 September 2025.
The Swiss government is currently assessing the EU’s restrictive measures under the 18th sanctions package that have not yet been implemented in Switzerland.
In addition, on 13 August 2025, the Swiss government issued the Ordinance on the Harmonization of Sanctions Ordinances (see here), with the aim of strengthening the protection of humanitarian activities as well as clarifying and harmonizing several restrictive financial measures. This ordinance amends several sanctions ordinances, including the Ukraine Ordinance and the Belarus Ordinance, and will come into force on 15 September 2025.
The most significant newly adopted measures are detailed below.
Ukraine Ordinance
- Fourteen individuals and forty-one entities have been included in Annex 8 of the Ukraine Ordinance. As such, these individuals and entities are subject to the asset freeze and prohibition against transferring or making available funds or economic resources under Article 15, and are also subject to the entry and transit ban into or through Switzerland under Article 29. These listings include individuals and entities domiciled abroad that are known to have transferred restricted goods to Russia, participated in schemes to circumvent sanctions or be otherwise connected with transporting or selling crude oil or petroleum products originating in or exported from Russia. Non-Russian persons have also been listed.
- Twenty-six entities have been included in Annex 2 of the Ukraine Ordinance, which will make them subject to the trade restrictions on (i) dual-use goods, and goods and technology that might contribute to Russia’s military and technological enhancement or the development of the defense and security sector, (ii) the provision of ancillary services, and (iii) transactions involving intellectual property rights or trade secrets in connection with these goods and technology under articles 4 and 5. The newly designated entities, which include entities based in China, Hong Kong SAR and Türkiye, are now subject to stricter export control measures because some are believed to be providing assistance in the circumvention of export restrictions on unmanned aerial vehicles.
- One hundred and five objects have been included in Annex 33 of the Ukraine Ordinance, thereby becoming subject to the trade restrictions and the prohibition against chartering, operating, or providing a crew or financial and technical services with respect to the listed vessels, as provided in Article 12d. These vessels primarily form part of Russia’s shadow fleet and are known to transport crude oil or petroleum products from Russia, circumventing the oil price cap, as well as military goods and technology to Russia. The newly listed vessels also include those that contribute to the exploitation, development or expansion of Russia’s energy sector; those that transport stolen Ukrainian grain or cultural goods; and those that are owned, chartered or operated by designated persons.
- The price cap for crude petroleum or oils obtained from bituminous minerals has been reduced from USD 60 to USD 47.60 per barrel. Accordingly, these products will only be exempted from the restrictive measures under Article 12b of the Ukraine Ordinance if their purchase price does not exceed the price ceiling of USD 47.60 per barrel. So far, Switzerland has not implemented the EU’s new automatic and dynamic price cap mechanism provided for in Article 3n(11) of Council Regulation (EU) No. 833/2014. However, this could be included as part of the 18th package’s further implementation.
- The prohibition against transferring or making funds or economic resources available does not apply to interest and other income credited to frozen accounts, or to payments based on existing contracts or payments based on arbitral awards or judicial or administrative decisions issued or enforceable in Switzerland, the European Economic Area or the United Kingdom, as long as the credited amounts remain frozen (new Article 15, paragraph 2ter). The same applies to funds transferred by third parties to frozen accounts held by designated persons (new Article 15, paragraph 2quater), which aligns with the answer provided in the State Secretariat for Economic Affairs’ (SECO) current guidance (Auslegungshilfe Sanktionsmassnahmen) (see question 1.12).
- It has been clarified that the reporting obligations regarding freezing accounts and economic resources apply to all organizations — not only financial institutions — that hold or manage funds, or are aware of funds or economic resources that are likely to be subject to the asset freeze (amended Article 16, paragraph 1). However, financial institutions must submit a report to SECO by 15 February each year detailing the amounts held or managed as of 31 December the previous year (new Article 16, paragraph 1quater). Credits to frozen accounts held by designated persons must be reported to SECO without delay (new Article 16, paragraph 1quinquies). It has also been clarified that reports under Article 16 must include: (i) the names of the beneficiaries; (ii) the purpose and value of the frozen funds and economic resources; and (iii) in the case of credits, the names of the issuers (amended Article 16, paragraph 2). This generally aligns with the answers provided in SECO’s current guidance (see questions 1.5, 1.6 and 1.12).
- In proceedings to enforce a claim, the claimant will bear the burden of proving that the claim is not unenforceable due to the prohibition set out in Article 30, paragraph 1, namely that: (i) the claim is not impaired by applicable sanctions; and (ii) the claimant is not a designated person, is not a person owned or controlled by a designated person, is not a Russian national and is not located in the territories designated under Annex 6 of the Ukraine Ordinance (new Article 30, paragraph 2).
Belarus Ordinance
- Eight entities have been included in Annex 13 of the Belarus Ordinance, which makes them subject to the asset freeze and the prohibition against transferring or making available funds or economic resources under Article 12, as well as an entry and transit ban into or through Switzerland under Article 25. All of these entities are linked to the military industry in Belarus and, therefore, support its defense and security capabilities. This measure mirrors the EU listings that came into force on 18 July 2025, ahead of the consideration of additional EU restrictive measures against Belarus.
- The prohibition against transferring or making available funds or economic resources does not apply if it is necessary for the performance of humanitarian activities by public bodies or by companies and organizations that receive federal contributions for these activities (new Article 12, paragraph 2ter).
- In line with the Ukraine Ordinance, there are exceptions to the asset freeze and the prohibition against transferring or making funds or economic resources available with regard to crediting to frozen accounts (new Article 12, paragraph 2quater-2quinquies).
- Licensing grounds have been harmonized with respect to the same financial sanctions (amended Article 12, paragraphs 3 and 4), which is also in line with the Ukraine Ordinance.
- The reporting obligations on frozen funds and economic resources have been clarified and extended (amended Article 13, paragraphs 1-4), in line with the Ukraine Ordinance.
- The burden of proof has been shifted with regard to claims impaired by sanctions (new Article 27, paragraph 2), which also mirrors the Ukraine Ordinance.
Moldova Ordinance
- Seven individuals and three entities have been included in the Annex of the Moldova Ordinance, making them subject to the asset freeze and prohibition against transferring or making available funds or economic resources under Article 12, as well as the entry and transit ban into or through Switzerland under Article 25. The newly listed individuals and entities are known to have been involved in Russian campaigns to influence the EU accession referendum and the 2024 presidential elections.
- Articles 2, 4 and 6 of the Moldova Ordinance have been amended to align with the amendments to the financial sanctions and related reporting obligations in the Ukraine Ordinance and Belarus Ordinance.
Conclusion
These new measures mark the first step in the implementation of the restrictive measures adopted by the EU in July 2025 with regard to the Russia, Belarus and Moldova sanctions. In the same press release announcing these listings, the Swiss government announced that it is examining the implementation of the remaining restrictive measures forming part of the 18th sanctions package. We can therefore expect the next amendment to the Ukraine Ordinance to cover the remaining measures of the EU’s 18th sanctions package, thereby closing the current gap between the EU and Switzerland, sometime in September.
Baker McKenzie Switzerland
