Further to the expansion of EU sanctions on 12 May 2014, the Swiss Federal Department of Economic Affairs (“EAER“) has today updated its own list accordingly of persons subject to anti-circumvention measures. The 13 additional individuals and two entities named by the EU as subject to sanctions have now been included in the annex to the Swiss ordinance dated 2 April 2014 on measures to prevent the circumvention of international sanctions connected with the situation in Ukraine.

It should be restated that Switzerland has not currently imposed sanctions itself against these individuals, but is enacting these restrictive measures to ensure that its territory will not be used to evade any sanctions imposed by the international community. Nonetheless, the addition of the 13 additional individuals and two entities to the ordinance annex means that financial intermediaries based in Switzerland may no longer enter into new business relationships with them. Existing business relationships may remain in effect, but now require notification to the State Secretariat for Economic Affairs of the existence of the relationship.

The EAER’s list now contains a total of 61 individuals and two entities, PJSC Chernomorneftegaz and Feodosia. The measures come in to force tomorrow, 20 May 2014, at 12.00pm CEST (11.00am GMT, 6.00am EST). The EAERs update notification may be found here, and a consolidated version here.

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