On 1 June 2025, the revised Swiss Ordinance on Measures against Belarus (“Belarus Ordinance“) entered into force, thereby implementing the EU’s latest Belarus sanctions. These sanctions had been adopted alongside the EU’s 16th sanctions package against Russia on 24 February 2025, which Switzerland implemented on 15 May 2025 (see blog post here). With this revision of the Belarus Ordinance, Switzerland continues to align its sanctions regime against Belarus with the sanctions against Russia, thereby preventing the circumvention of Russia sanctions in Europe (see press release here [bottom]).
The Belarus Ordinance’s newly introduced measures include the following:
Export restrictions
- The restriction on the sale, etc. of as well as the provision of any ancillary services in connection with dual-use goods and goods contributing to military and technological enhancement has been expanded to now prohibit the sale, etc. to certain (military) final recipients listed in Annex 5 to the Belarus Ordinance (Articles 4 and 5 of the Belarus Ordinance). The listed entities include, among others, the Belarus Ministry of Defense, the Belarusian State Security Committee, engineering firms and repair plants.
- Additionally, many of the grounds that previously qualified for exception to the sale, etc. of such goods have now been reclassified as exemptions, i.e., licensing requirements, thus significantly tightening the regulatory framework (Article 7 paragraph 1-ter of the Belarus Ordinance).
- A new provision targeting software for the energy sector has been added (Article 10c-bis of the Belarus Ordinance). This provision prohibits the sale, etc. of software for the energy sector to or for use in Belarus as listed in the new Annex 7b to the Belarus Ordinance. Furthermore, providing services of any kind, including financial services, brokerage and technical assistance, as well as granting financial resources is prohibited. Related intellectual property rights are equally affected.
- In the context of tightened export restrictions, the Annexes to the Belarus Ordinance listing affected goods have also been amended. For example, the list of goods for industrial strengthening that are prohibited from being transited through Belarus has been expanded to include, among others, certain catalysts, flat-rolled steel products, and various parts and accessories for specific motor vehicles (Annex 20 to the Belarus Ordinance).
Extended import restrictions
- Besides new export and transit restrictions, the amended Belarus Ordinance also expands the restrictions on the import, etc. of a variety of goods. Under Annex 22 to the Belarus Ordinance, raw aluminum, raw iron, cement, certain fertilizers and pneumatic tires are now considered economically significant goods.
Financial restrictions
- A new exception to the asset freezing rules set out in Article 12 of the Belarus Ordinance now allows banks, etc. to release certain frozen funds or economic resources if needed to process transfers to or within Switzerland, in case a listed company or organization is involved as a sending or intermediary bank — provided that the transfer is between individuals, companies, or organizations that are not subject to the asset freeze (Article 12 paragraph 2bis of the Belarus Ordinance).
- One final noteworthy change relates to the receipt of deposits: Receiving deposits from natural persons resident in Belarus as well as companies and organizations established in Belarus was previously prohibited. With the entry into force of the revised Belarus Ordinance, this prohibition now also applies to deposits received from banks established in Belarus and companies, organizations, and banks whose majority of shares are held directly or indirectly by Belarusian nationals or by natural persons resident in Belarus (Article 18 paragraph 1 a-d of the Belarus Ordinance).
Conclusion
With this step following the implementation of the EU’s 16th sanctions package against Russia, Switzerland has now realigned its measures against Belarus with those of the EU and brought them into closer correlation with the sanctions imposed on Russia. As noted during the latest round of Russia-related sanctions, these measures were introduced with a considerable delay compared to the EU, which has already adopted its 17th sanctions package against Russia and announced that it is working on an 18th package — though these do not (yet) include additional sanctions against Belarus.
