Swiss sanctions against Russia – Further alignment with the EU – Implementation of the 19th Sanctions Package

1. Introduction

On 25 February 2026, the Swiss Federal Council adopted further sanctions against Russia with a view to mirroring the latest measures imposed by the EU on 23 October 2025. The corresponding amendments to the Ordinance on measures in connection with the situation in Ukraine ("UKRO") entered into force on 26 February 2026.

The Swiss State Secretariat for Economic Affairs ("SECO") simultaneously updated its FAQ guidance to clarify the scope and application of UKRO.

Redline comparisons and English translations of the UKRO and FAQ are available as follows:

• UKRO (as of 26 February 2026 and a redline against the version of 30 October 2025): here and here, respectively.
• SECO FAQ (as of 26 February 2026 and a redline against the version of 30 October 2025): here and here, respectively.

2. Key elements of the amended UKRO

The newly adopted amendments intensify existing restrictions in relation to energy-related activities, crypto-assets and associated services, financial sector restrictions and additional trade and services restrictions. The following highlights some of the most relevant amendments:

Liquefied natural gas ("LNG") (Article 12g UKRO; transitional clause in Article 35 (39) UKRO)

Article 12g UKRO introduces a new prohibition relating to LNG of Russian origin. The provision is subject to staggered entry into force.

Article 12g (2) UKRO, which entered into force on 26 February 2026, prohibits the provision of financial services, brokering services, technical assistance and the provision of funds or economic resources in connection with LNG transactions falling within the scope of Article 12g UKRO.

Article 12g (1) UKRO, which enters into force on 25 April 2026, establishes the core prohibition on the purchase, import, transit and transport of LNG originating in or exported from Russia.

The transitional clause in Article 35 (39) UKRO allows the performance of long-term contracts concluded before 26 February 2026 until 1 January 2027, provided certain conditions are met (including, notably, that the contracts have not undergone "significant amendments").

The updated SECO FAQ provides operational colour on the notion of "significant amendments" (modifications significatives) under Article 35 (39) UKRO, indicating that various changes (such as reductions in quantities, reductions in prices/commissions, changes to confidentiality clauses, operational procedures, addresses, intra-group transfers of contractual commitments, amendments resulting from litigation/arbitration, and changes in domestic delivery points) are treated, for these purposes, as not constituting "significant amendments" (cf. new FAQ section 2.3).

Crypto-assets (Articles 20 and 20a UKRO)

The amendments introduce additional restrictions relating to cryptoassets through modifications to Article 20 UKRO and the introduction of a new Article 20a UKRO, together with a new Annex 13a UKRO.

Article 20 UKRO continues to prohibit, inter alia, the provision on a professional basis, directly or indirectly, of services relating to cryptoassets to Russian nationals, persons residing in Russia and entities established in Russia. The overall structure of the provision remains broadly unchanged compared to the previous version.

However, the wording of Article 20 (2) UKRO has been refined and the categories of cryptoasset-related services covered by the prohibition are now described in greater detail. In particular, the provision now expressly refers to services relating to cryptoasset wallets, accounts, custody services, payment services involving cryptoassets and electronic money services involving cryptoassets.

The updated SECO FAQ further clarifies the scope of the notion of services relating to cryptoassets, which is interpreted in line with the corresponding EU provisions (cf. FAQ sections 2.9.2 and 2.9.3).

According to the revised FAQ, the terms "services relating to cryptoassets" include in particular:

• the custody and administration of cryptoassets on behalf of clients;
• the operation of cryptoasset trading platforms;
• the exchange of cryptoassets against other cryptoassets;
• the execution of orders relating to cryptoassets on behalf of clients;
• the placement of cryptoassets;
• the reception and transmission of orders relating to cryptoassets;
• advice relating to cryptoassets;
• portfolio management relating to cryptoassets; and
• transfer services relating to cryptoassets on behalf of clients.

From a practical perspective, this confirms that Article 20 UKRO covers the full range of cryptoasset services, including custody, trading and transfer services, and is not limited to payment-related activities.

In addition, the FAQ clarifies that the notion of payment instrument includes any personalised device or procedure agreed between the user and the payment service provider and used to initiate a payment order. The notion of electronic money is intepreted as monetary value stored electronically and representing a claim on the issuer, issued against the receipt of funds and accepted by persons other than the issuer.

In addition, a new provision has been introduced in Article 20 (3^bis) UKRO, which provides that the prohibitions set out in Article 20 (2) UKRO do not prevent the provision of personalised security credentials necessary to access an account held with a financial institution or electronic money issuer established in Switzerland, a member state of the European Economic Area or a partner country.

The revised provision also introduces explicit wording addressing ownership, control and governance aspects in the cryptoasset context (Article 20 (2^bis) (b) UKRO). In particular, the restriction framework now extends to situations where a cryptoasset service provider is acquired, held or controlled by Russian nationals, persons residing in Russia or entities established in Russia, as well as to situations where such persons exercise management functions.

Alongside these adjustments, the amendments introduce a new Article 20a UKRO, which establishes a prohibition on participation, directly or indirectly, in transactions involving certain cryptoassets listed in Annex 13a UKRO. This provision applies irrespective of the identity or location of the counterparties.

At this stage, Annex 13a UKRO lists the rouble-backed stablecoin A7A5.

Transaction restrictions with certain banks and "mirror/successor" entities (Article 24c (1) UKRO; Annex 15b UKRO)

Article 24c (1) UKRO contains a targeted prohibition on transactions with (i) the banks and entities listed in Annex 15b UKRO, (ii) persons/entities acting on their behalf or under their instructions, and, as of 26 February 2026, (iii) banks or entities functioning as "mirror entities" or as successors to a bank or entity listed in Annex 15b UKRO.

The revised SECO FAQ provides additional guidance on the notion of "mirror entities" or "successor entities" within the meaning of Article 24c (1) (c) UKRO. According to the FAQ, an entity may be considered a mirror or successor entity where at least two indicators of continuity are present, such as substantial identity of transaction flows or data flows, continuity of branding or user interface, partial overlap of ownership or management, migration of users or continuity of technical infrastructure (cf. FAQ section 2.13.1).

Finally, Article 35 (27) UKRO provides for time-limited carve-outs (notably for certain pre-existing contracts involving specific entities listed in Annex 15b UKRO).

Restrictions linked to Russian special economic zones, innovation zones and preferential zones (Article 28b^bis UKRO)

Newly introduced Article 28b^bis UKRO addresses Russian special economic zones, innovation zones and preferential zones identified by reference to Annex 14b UKRO.

Under Article 28b^bis (1) UKRO, it is prohibited, directly or indirectly, to engage in certain investment and participation activities connected with entities established in the zones listed in Annex 14b UKRO.

The prohibition covers in particular:

• the acquisition or extension of participations in entities established in the listed zones;
• the granting of loans or credit to such entities;
• the creation of joint ventures with such entities; and
• the provision of investment services relating to such entities.

The scope of the prohibition is determined by reference to the geographical location of the entity concerned, rather than by reference to the nationality of the shareholders or beneficial owners. Accordingly, the prohibition may apply even where the counterparty itself is not designated, provided that it is established in a zone listed in Annex 14b UKRO.

The prohibitions set out in Article 28b^bis (1) (b), (d), (f) and (h) UKRO enter into force only on 27 May 2026. Other elements of Article 28b^bis UKRO, including the definitional and structural provisions, apply as from 26 February 2026.

Further, the ordinance introduces a transitional clause allowing the performance of contracts entered into before 26 February 2026, where necessary, until 27 May 2026, in relation to activities falling within the scope of Article 28b^bis UKRO.

Finally, a specific derogation mechanism is introduced in Article 30c UKRO, under which SECO may authorise derogations from Article 28b^bis UKRO where this is necessary for:

• the disposal of assets in the Russian Federation; or
• the termination of activities in the Russian Federation.

This derogation framework follows the logic of an orderly exit mechanism, allowing Swiss operators to unwind existing positions while preventing new investment activity.

Services restrictions (Article 28e UKRO)

The amendments introduce significant extensions to the service prohibitions set out in Article 28e UKRO, in particular in relation to advanced digital and technology services.

In particular, the revised provision introduces new prohibitions relating to:

• commercial space-based Earth observation or satellite navigation services;
• artificial intelligence services consisting of access to models or platforms for training, fine-tuning and inference;
• high-performance computing services, including access to graphics processing unit-accelerated computing or quantum computing services.

These services are typically provided remotely and may consist in granting access to technological infrastructure or computing capabilities rather than delivering software or consulting services in the traditional sense.

The prohibitions relating to these advanced technology services enter into force on 27 March 2026. Until that date, the newly introduced service categories under Article 28e (1) (f) to (h) UKRO do not yet apply.

The amendments also introduce a separate prohibition relating to services directly linked to tourism activities in Russia under Article 28e (3) UKRO. This provision applies as from 26 February 2026, subject to a limited transitional regime provided for in Article 35 (40^bis) UKRO in relation to contracts entered into before 26 February 2026 and performed until 27 May 2026.

The same transitional rule also applies to the ancillary prohibitions under Article 28e (5) UKRO, which concern the provision of financing, technical assistance or other services in connection with restricted services.

A separate transitional provision is provided under Article 35 (41) UKRO for Article 28e (4) UKRO, which concerns software supply. Under this provision, the prohibition does not apply to the supply of banking and financial software listed in Annex 32, chapter 3, where the performance until 27 May 2026 of contracts entered into before 26 February 2026 so requires.

3. Additional updates in the SECO FAQ

In parallel with the amendments to the UKRO, SECO has published a revised version of its FAQ document.

While several elements of the updated FAQ correspond to the newly introduced provisions and are thus directly discussed above, the revised document also contains a number of additional clarifications, notably, the following:

Petroleum products refined from Russian crude oil (Article 12abis UKRO, FAQ section 2.1)

The updated FAQ clarifies that the prohibitions set out in Article 12a^bis (1) and (2) UKRO apply only where the relevant petroleum products are destined for Switzerland or transit through Switzerland. Accordingly, the purchase, import or transport of petroleum products refined from Russian crude oil by Swiss persons or entities is not prohibited where the destination is a third country located outside the EU and the EEA. This clarification confirms that Article 12a^bis UKRO does not establish a general prohibition on global trading activities by Swiss operators, but is limited to imports into Switzerland and transit through Switzerland.

Asset freeze: tax and court-fee refunds (Article 15 UKRO, FAQ sections 2.8.8 and 2.8.9)

The revised FAQ further clarifies that refunds of federal, cantonal or communal taxes, as well as reimbursements of court costs, in favour of sanctioned persons do not constitute a prohibited making available of funds within the meaning of Article 15 (2) UKRO. Such payments are permitted provided that they are credited to accounts frozen pursuant to Article 15 (1) UKRO and remain blocked.

Reconstruction-related payments involving Ukraine

The updated FAQ confirms that payments relating to international technical assistance and reconstruction projects involving Ukraine are in principle permitted, provided that:

• the beneficiary is not subject to the prohibition on making funds available under Article 15 (2) UKRO, and
• the restrictions relating to the designated territories listed in Annex 6 UKRO (Article 25 UKRO) are respected.

Preventive asset freezes (Article 15 UKRO, FAQ section 1.9)

The revised FAQ clarifies that assets or economic resources that have been frozen on a preventive basis may be released without further consultation with SECO once SECO has issued a decision confirming that the asset freeze is not applicable.

In such cases, a written notification from SECO confirming the release is considered sufficient.

4. Reporting obligations – Reminder of key deadlines

[1]     Official SECO templates are published here: Link.

5. Due diligence – Reminder for financial institutions

Financial institutions should remain particularly vigilant to the risk of indirectly facilitating restricted transactions through providing financial services or financing. Indeed, in addition to prohibiting specific commercial activities, Swiss sanctions also restrict the financing of such activities, including the provision of loans, credit facilities, leasing, guarantees and insurance when linked to transactions involving sanctioned entities or sectors, as well as financial services more generally in certain specific cases.

This is particularly relevant when dealing with counterparties in jurisdictions considered to be "friendly" under Russian legislation, where there is an increased risk of sanctions circumvention. Financial institutions should ensure that financial services they provide do not indirectly support transactions that ultimately fall under Swiss sanctions prohibitions. In this context, financial institutions should also take into account the supervisory expectations of the Swiss Financial Market Supervisory Authority (FINMA). In its supervisory practice, FINMA has emphasised that sanctions compliance forms part of the broader organisational and risk-management obligations of financial institutions, and that institutions are expected to implement effective controls to detect potential sanctions violations.

A notable risk area is the crude oil sector, where transactions involving vessel leasing, shipping or crude oil trading require enhanced due diligence. If a financial institution provides financial services – including payments processing or treasury management – to a client involved in vessel chartering, for example, where vessels may be used to transport Russian crude oil, the financial institution should verify that such financial services do not indirectly facilitate transactions that breach price cap regulations.

The prohibition on certain transactions involving Russian infrastructure under Article 24d UKRO requires enhanced diligence efforts on transactions with potentially relevant touchpoints to assess compliance with the ban, applicable exemptions, and, as the case may be, notification obligations.

In addition, the expansion of service restrictions under Article 28e UKRO may affect financial institutions providing or financing digital or technology-related services, including cloud-based services and other remotely delivered services. Financial institutions should ensure that payment flows or financing arrangements do not support the provision of restricted services to Russian counterparties.

The newly introduced cryptoasset restrictions under Articles 20 and 20a UKRO also require particular attention. Financial institutions should assess whether clients engage in cryptoasset transactions or maintain relationships with cryptoasset service providers that may fall within the scope of the prohibitions, including transactions involving cryptoassets listed in Annex 13a UKRO.

Further, recent U.S. sanctions developments illustrate the growing expectation that foreign financial institutions also manage exposure to U.S.-designated Russian actors. On 22 October 2025, the U.S. Treasury Department (OFAC) designated two major Russian oil companies under Executive Order 14024. Although these measures are not part of Swiss law, Swiss actors ahave to be aware that persons that continue to do business with or involving designated persons or their blocked subsidiaries risk being designated themselves pursuant to E.O. 14024 for having "materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of" a person blocked pursuant to the said Executive Order.

In its 2024 Trilateral Compliance Note (available here), the DOJ, OFAC and BIS recalled the extraterritorial expectations of U.S. authorities toward non-U.S. persons and foreign subsidiaries of U.S. companies.

To manage such risks effectively, financial institutions should consider implementing a comprehensive risk management approach, including:

• Enhanced due diligence procedures, ensuring verification of counterparties, beneficial owners and end-users, respectively destination of restricted goods (e.g., oil, luxury goods, etc.) to assess potential exposure to sanctioned transactions.
• Explicit contractual representations and warranties, requiring clients to certify compliance with applicable sanctions regimes, respectively certifications that certain goods will not be sourced from or delivered to Russia or other restricted regions.
• Continuous monitoring of payment flows and transaction structures, particularly in cases where financial services are provided to clients operating in high-risk jurisdictions or where there are indications of re-export or indirect trade financing.
• Internal escalation procedures, ensuring that potential red flags – such as complex trade routes, non-transparent payment structures or counterparties with previous sanctions exposure – are promptly reviewed by compliance teams.

Given the evolving regulatory landscape, financial institutions should regularly review and strengthen their internal risk management frameworks to ensure full compliance with Swiss and international sanctions.

6. Future developments

Sanctions are amended and adapted on an ongoing basis. Given the importance of the topic and the potentially serious legal and reputational consequences of a breach, it is essential to keep abreast of the latest measures and any guidance issued by the Swiss government. We are monitoring these developments closely.

At this juncture, the introduced restrictions raise a number of interpretation and implementation questions. Some of those questions are expected to be clarified based on EU sanctions guidance and FAQs, if any, whereas other issues will require formal confirmation from SECO. We are working with our clients to clarify the expectations of competent authorities and to find practical solutions for an efficient operational implementation of the sanctions framework.

The European Union is already discussing a possible 20^th sanctions package, and further alignment measures by Switzerland cannot be excluded.

7. Useful links

Given the fluid nature of the sanctions, we enclose some relevant resources which we trust will be of assistance for monitoring the developments:

7.1 Swiss Sanctions

UKRO, as of 26 February 2026

• Official publication:
  • UKRO German version
  • UKRO French version
  • Unofficial English translation
  • Redline against the version of 30 October 2025 (English)

SECO FAQ, as amended on 26 February 2026

• Official publication:
  • German version
  • French version
  • Unofficial English translation
  • Redline against the version of 30 October 2025 (English)

7.2 EU Sanctions

• Consolidated texts of sanctions regulations
  • Consolidated text of Regulation (EU) No 833/2014 (Russia)
  • Consolidated text of Regulation (EU) No 269/2014 (Ukraine territorial integrity)
• Compilation of frequently asked questions regarding EU sanctions available here: link.

Please do not hesitate to contact us in case of any questions.

You may reach out to your usual contact at our firm or direct any sanction-specific queries to our dedicated task force at sanctions@clutterlenzstaehelin.com.

You will find a summary of some of the recent work conducted by our sanctions task force – including advice on sanctions compliance, assistance with the review and implementation of internal policies and procedures, support with monitoring regulatory developments and guidance across sectors such as trading, shipping, industrial and luxury goods, as well as our involvement in internal audits and reviews aimed at helping clients assess and strengthen their sanctions compliance frameworks – in a two-page document available here.

Legal Note: The information contained in this Smart Insight newsletter is of general nature and does not constitute legal advice.