In view of Russia’s continuing military intervention in Ukraine, the Swiss Federal Council at an extraordinary meeting on 28 February took the decision to adopt the packages of sanctions imposed by the EU on 23 and 25 February, respectively. Switzerland will implement the sanctions in coordination with the EU and, as previously, will examine each further package of sanctions imposed by the EU on a case-by-case basis. The Swiss Finance Minister also announced that Switzerland would support international measures regarding the exclusion of certain Russian banks from SWIFT.
The existing “Ordinance on measures for the avoidance of the circumvention of international sanctions in connection with the situation in the Ukraine” has been renamed to “Ordinance on Measures in connection with the situation in the Ukraine”, and the revised Ordinance has taken effect on 28 February at 6pm CET. The assets of the persons and companies listed in Annex 3 to the Ordinance are frozen with immediate effect, and the ban on entering into new business relationships, so far only applicable to financial intermediaries, is extended to a general ban on doing business with listed parties, i.e. to full-fledged financial sanctions, subject to authorizations of certain exemptions (and specific exemptions in relation to Bank Rossiya, PROMSVYAZBANK and Vnesheconombank (VEB). In addition to the list already adopted on 25 February, Russian President Vladimir Putin, Prime Minister Mikhail Mishustin and Foreign Minister Sergey Lavrov have also been designated. Moreover, the existing capital market restrictions regarding the issuance of and trading in financial instruments and the grant of loans to sectorally listed parties, have been modified to entail bans rather than licensing obligations.
Furthermore, the ban on imports, exports and investments concerning Crimea and Sevastopol, which has already been in place since 2014 even under the anti-circumvention measures, has now been extended to those territories of the Ukrainian regions of Donetsk and Luhansk which are no longer under the control of the Ukrainian government.
The Swiss government has also decided to partially suspend the 2009 agreement on visa facilitation for Russian nationals and to impose entry bans against a number of individuals who have a connection to Switzerland and are close to the Russian president.
In addition, again in line with airspace closures in other European countries, Swiss airspace has been closed to all flights from Russia and to all movements of aircraft with Russian markings since 3pm CET on 28 February, with the sole exception of flights for humanitarian, medical or diplomatic purposes.
