Switzerland imposes further financial and trade sanctions on Russia

On March 4th 2022, the Swiss Federal Council decided to completely revise the “Ordinance on Measures connected with the Situation in Ukraine” which was recently amended on February 28th 2022 (and first issued in 2014).

This wide new revision greatly extends existing sanctions against Russia while also adopting various new measures and restrictions similar to those recently imposed by the EU in the trade and financial sectors. These measures prohibit exports of high-tech, dual use and aircraft related goods as well as gas and/or oil equipment to Ukraine and Russia. Also, the new sanctions add several new asset freezes and constrict numerous financial and monetary sanctions.

On March 4th, the asset freeze has been extended to an additional 122 Russian and Belarusian individuals and one new Russian entity. Under this measure, all assets controlled or owned by entities, companies or individuals listed in Annex 8 of the revised Ordinance became frozen from 6 p.m. the same day. This freeze also prohibits the provision of economic resources or assets to these entities, companies and individuals, whether directly or indirectly. In addition, this measure enforces a declaration requirement under which entities that manage or hold assets that should be frozen, must declare those to the Swiss State Secretariat for Economic Affairs (SECO).

Certain Swiss capital market sanctions restricting specific dealings in new equity and debt issued by certain Russian companies, banks and affiliates (that have been introduced in 2014) have been amended and revised significantly. On March 4th, four additional Russian banks (and other corporations) became subject to the Swiss capital market sanctions. These banks include: Bank Otkritie, Alfa Bank, Bank Rossiya. New restrictions have also been imposed on the Central Bank of Russia, banning it from all transactions related to the management of it’s assets and reserves. Also, a new prohibition was introduced on the sale, transfer, supply or export of the Swiss franc or euro-denominated many notes to any natural or legal person, body or entity in Russia or to Russia.

In addition to the numerous financial restrictions, several trade restrictions have been imposed as well. One critical prohibition involves the oil and gas equipment (energy) sector. The new sanctions are similar to the ones adopted by the EU in 2014 and subject the supply, sale, export or transit of listed goods for the oil industry to authorization. More information on the new measures, sanctions and restrictions imposed by Switzerland on March 4th 2022 can be found here.