On 31 October 2022, the Swiss Department of Economic Affairs, Education and Research (the “EAER”) introduced three Iranian individuals and one organisation to Annex 8 and thus subjected them to an asset and economic resource freeze pursuant to Article 15 of the Swiss Ordinance on Measures connected with the Situation in Ukraine (the “Ukraine Ordinance”). This inclusion is again in line with the actions taken by the EU on 20 October 2022. The amended annex entered into force on 1 November 2022 at 18:00 CET.
The new designated individuals are:
- Mohammad Hossein Bagheri: the Chief of Staff of Iran’s Armed Forces and supervisor of the military Unmanned Aerial Vehicle programme (i.e. the supply of drones) which plays a fundamental role in Iran’s defence cooperation with Russia.
- Syed Hojatollah Qureishi: the Head of the Supply, Research, and Industrial Affairs Division at the Iranian Ministry of Defense and Armed Forces Logistics (“MODAFL”) and responsible for negotiating the agreement with Russia in relation to the supply of Iranian-made Unmanned Aerial Vehicles for their use in the war against Ukraine.
- Saeed Aghajani: the Commander of the Islamic Revolutionary Guard Corps – Aerospace Force overseeing and directing the planning, equipment and training for Iran’s Unmanned Aerial Vehicles operation.
- Shahed Aviation Industries: an Islamic Revolutionary Guard Corps Aerospace Force-linked company in Iran responsible for the design and development of the Shaheed series of Iranian Unmanned Aerial Vehicles supplied to the Russian Federation and used in the war against Ukraine.
The EAER and the Swiss Federal Department of Foreign Affairs (the “FDFA”) decided to restrict their intervention to the inclusion of these high-profile Iranian military personalities and entity to the list of designated parties under the Ukraine Ordinance due to their involvement in drone deliveries to Russia for their use in the war against Ukraine. However, unlike the EU, Switzerland has decided not to implement further sanctions measures against Iran, stressing the five protecting power mandates (USA in Iran, Iran in Saudi Arabia/Saudi Arabia in Iran, Iran in Canada, Iran in Egypt) that Switzerland maintains in connection with Iran. Furthermore, Switzerland continues to uphold sanctions against Iran under the Swiss Ordinance on Measures against the Islamic Republic of Iran dated 11 November 2015 (the “Iran Ordinance”), in line with the JCPOA.
The latest version of the Ukraine Ordinance is here.
The latest version of the Iran Ordinance is here.
The updated list of sanctioned individuals and entities under Annex 8 of the Ukraine Ordinance is here.
