Judgment 4A_537/2025 of 28 April 2026 In its recent judgment 4A_537/2025 of 28 April 2026, the Swiss Federal Supreme Court upheld the judgment of the Commercial Court of the Canton of Zurich of 17 September 2025 (HG230210-O) and provided important guidance on the interpretation of Swiss sanctions laws – specifically on the asset freeze and reporting obligations imposed on financial institutions holding or managing funds. The Swiss Federal Supreme Court clarified, first, the evidentiary threshold…
On 13 August 2025, the Swiss government adopted the Ordinance on the harmonization of sanctions ordinances (“Ordinance”), introducing a number of provisions relating to financial sanctions and their exceptions and derogations in relation to 14 of the 28 sanctions regimes in force in Switzerland (already briefly mentioned here). The Ordinance will come into effect on 15 September 2025. The sanctions regimes affected by the amendments introduced by the Ordinance are the following: In essence, the…
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…
On 2 April 2025, the Swiss Federal Council announced an update to the Swiss dual-use goods control lists. This change represents a noteworthy departure from the international export control regimes that have traditionally consensually updated these lists but that are currently blocked due to ongoing geopolitical tensions. As a result, Switzerland has now issued revised lists in line with key trade partners. Dual-use goods are goods that can be used for both civilian and military…