Swiss sanctions against Russia – Further alignment with the EU – Implementation of the 20th Sanctions Package

On 19 August 2026, the Swiss Federal Council adopted further sanctions against Russia with a view to mirroring the latest measures imposed by the EU on 23 April 2026. The corresponding amendments to the Ordinance on measures in connection with the situation in Ukraine (“UKRO”) entered into force on 20 August 2026[1].

[1]     Unofficial translation into English of the UKRO as of 20 August 2026 and a redline against the version of 26 February 2026 are available here and here, respectively

• Military/technological and industrial goods (Articles 2a, 4, 5, 9a, 9b, 11, 11a UKRO)

Significant expansions to existing export prohibitions:

• Article 2a UKRO: The ordinance of 19 August 2026 rewrites paragraphs (1), (1bis) and (3bis) of Article 2a, with effect from 1 September 2026. The amended text removes all references to Ukraine, so that the prohibitions on the sale, delivery, export and transit of military equipment under these paragraphs – as well as the associated restrictions on financial services, brokerage, technical assistance and other related services – will apply exclusively to the Russian Federation.

Although the temporary provision introduced by RO 2023 452, which maintained the Ukraine-related restrictions under these same paragraphs, had previously been extended until 1 March 2030 (RO 2025 779), the amended wording of UKRO prevails, and these sanctions-based restrictions will effectively cease to apply to Ukraine as from 1 September 2026. Export and transit prohibitions arising from neutrality law will continue to be governed by existing legislation on military goods and dual use goods control (see Federal Council communication of 22 April 2026).

The revised Article 2a also introduces a new paragraph (4bis) providing an exemption for military forensic-technical analysis of goods originating from the Russian Federation recovered in Ukraine. In addition, paragraph (6bis), which provided a derogation for goods delivered to countries listed in Annex 34 for incorporation into military equipment, is abrogated as from 1 September 2026.

• Articles 4 and 5: Paragraphs (1)(b), (2)(b), (2bis)(b) and (3) of Articles 4 and 5, which imposed authorization requirements and restrictions on exports of dual-use and military/technological goods to Ukraine, are abrogated as from 1 September 2026.
• Article 9a UKRO: Extended to cover maritime navigation goods with strengthened IP/trade secret transfer prohibitions, as from 1 September 2026.
• Article 9b UKRO: Extended transit prohibitions for jet fuels and additives through Russia, as from 1 September 2026.
• Article 11a UKRO: New Annex 23b added with additional energy-sector goods subject to export restrictions.

• Tanker vessels (Article 12c UKRO)

New Article 12c UKRO introduces a prohibition on the sale, supply, export, transport and transit of tanker vessels (tariff heading 8901 20 00) for transporting crude oil or petroleum products listed in Annex 24 to persons, companies or entities in Russia or for use in Russia.

Where tanker vessels are sold or otherwise transferred to a third country outside the EEA or an EEA partner country, exporters must contractually prohibit their counterparty from reselling or further transferring the vessels to Russia or for use in Russia.

Sales and transfers of tanker vessels to third countries must be notified to the Swiss State Secretariat for Economic Affairs (“SECO”) without delay, including details of buyer/seller identity, shareholding, management composition, and the vessel’s IMO identification number and call sign.

• Icebreakers and LNG carriers (Article 12e UKRO)

New Article 12e UKRO prohibits the provision of services of any kind, including financial services, brokerage services, technical assistance and the provision of funds in connection with:

• Icebreakers (tariff heading ex 8906 90) when the vessel flies the Russian flag, is certified by the Russian ship register, is owned or managed by a Russian person/entity/body, operates in Russia, or is destined for use in Russia;
• LNG carriers (tariff heading ex 8901 20) under the same conditions.

The prohibitions do not apply to: seeking a place of refuge, entering a port for maritime safety or life-saving purposes, and preventing or mitigating urgent events with serious health, safety or environmental impacts or responding to natural disasters.

Note: The provisions concerning LNG carriers under Article 12e(2)(d) and (e) enter into force only on 1 January 2027.

• LNG terminals (Article 12h UKRO)

New Article 12h UKRO prohibits the provision of services in connection with LNG terminals to legal persons, organisations or bodies in Russia.

This provision enters into force on 1 January 2027.

• Anti-Circumvention Tool – Exports to Kyrgyzstan (Article 14h UKRO; Annex 38)

For the first time, Switzerland activates the “anti-circumvention tool”. New Article 14h UKRO prohibits the sale, supply, export, transit and transport of goods and technologies listed in Annex 38 to third countries designated in that annex. At this stage, the designated country is Kyrgyzstan.

The prohibition extends to related services (including financial services, brokerage, technical advice) and IP/trade secret transfers connected with the listed goods and technologies.

Derogation possibilities mirror those available under the UKRO for exports to Russia of the same goods/technologies.

• Crypto-assets and digital central bank currencies (Article 20a UKRO; Annex 13a)

Article 20a UKRO has been revised to expand the prohibition on direct or indirect participation in transactions involving crypto-assets listed in Annex 13a. The provision now also covers central bank digital currencies and assistance in developing such crypto-assets or digital currencies.

Annex 13a now lists: A7A5, RUBx (Rouble digital).

• Crypto-asset service providers and platforms (Article 20b UKRO)

New Article 20b UKRO prohibits legal persons, including financial institutions, from participating directly or indirectly in any transaction with:

• Legal persons, entities or bodies established in Russia that provide crypto-asset services; or
• Platforms established in Russia that enable the exchange or transfer of crypto-assets.

Natural persons are prohibited from participating directly in such transactions.

A narrow exception applies for official activities of diplomatic or consular representations and international organisations enjoying immunities under international law.

A new derogation mechanism is introduced in Article 30^csepties UKRO, under which SECO may authorize derogations from Article 20b where necessary for the disposal of assets in Russia or the cessation of activities in Russia.

• Managed security services (Article 28e(1)(i) UKRO)

The list of restricted services under Article 28e UKRO is expanded to include managed security services provided to the Russian government or to Russian-established entities.

This provision enters into force on 21 September 2026.

• Donations from the Russian government (Article 28g UKRO)

The prohibition on accepting donations, economic advantages or support from the Russian government, Russian state-controlled entities, and entities acting on their behalf is extended to:

• Research and innovation businesses and establishments implementing research and innovation measures;
• Research and educational institutions;
• Natural persons associated with the above.

Derogation possibilities are maintained where acceptance does not undermine democratic processes or foundations.

• Transaction prohibitions relating to certain listed persons (Articles 28i, 28j and 28k UKRO; Annexes 39 to 41)

Three new transaction prohibitions are introduced:

• Article 28i UKRO prohibits direct or indirect participation in any transaction with entities listed in Annex 39 that use intellectual property rights or trade secrets without authorisation.
• Article 28j UKRO prohibits direct or indirect participation in any transaction with persons listed in Annex 40 that have benefited from decisions taken under Russian Presidential Decree No. 302 of 25 April 2023 or related Russian legislation. Russian Presidential Decree No. 302 of 25 April 2023 established a legal framework allowing the Russian government to seize temporary external control over assets owned by investors from “unfriendly” foreign states.
• Article 28k UKRO prohibits direct or indirect participation in any transaction with persons listed in Annex 41, as well as persons that hold or control them.

Narrowly defined exceptions apply under Articles 28j and 28k, notably for pharmaceutical, medical, agricultural and food products, access to judicial proceedings and damages claims under Article 30f UKRO.

• Swiss judicial remedies (Articles 29d and 30f UKRO)

Article 29d UKRO is expanded: Swiss nationals, residents, and Swiss-established entities may now request Swiss courts to confirm the exclusive jurisdiction of the agreed arbitral tribunal. Courts may order persons not to initiate or pursue proceedings abroad; non-compliance gives rise to damages liability.

Article 30f UKRO establishes a right to claim damages before Swiss courts for direct or indirect losses (including legal costs) arising from claims pursued in non-Swiss/non-EEA jurisdictions by persons subject to Article 30 UKRO, or from abusive Russian court decisions, provided no effective remedy is available before the competent jurisdiction.

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

Financial institutions should remain particularly vigilant to the risk of indirectly facilitating restricted transactions through providing financial services or financing. Swiss sanctions prohibit not only specific commercial activities but also the financing of such activities, including loans, credit facilities, leasing, guarantees, insurance and other financial services.

Key areas of heightened vigilance include:

• The new crypto-asset restrictions under Articles 20a, 20b and 30csepties UKRO, requiring assessment of whether clients engage in transactions with Russian crypto-asset service providers or platforms;
• The tanker vessel and LNG-related prohibitions under Articles 12c, 12e and 12h UKRO, particularly for financial institutions involved in trade finance, shipping or vessel chartering;
• The activation of the “anti-circumvention tool” under Article 14h UKRO, requiring enhanced screening of export transactions to Kyrgyzstan;
• The expanded service restrictions under Article 28e UKRO (managed security services);
• The new transactions prohibitions under Articles 28i, 28j and 28k UKRO;
• The continued relevance of FINMA supervisory expectations regarding sanctions compliance as part of organisational and risk-management obligations.

Financial institutions should implement enhanced due diligence procedures, explicit contractual representations and warranties, continuous monitoring of payment flows and transaction structures, and internal escalation procedures for potential red flags.

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.

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 have 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.

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.

It is important to note that, in parallel with the measures against Russia, Switzerland also maintains and regularly updates sanctions against Belarus (RS 946.231.116.9). While the SECO FAQ states that, unless indicated otherwise, the interpretations contained in Chapter 2 of the FAQ are also valid for identical provisions of the Ordinance on measures against Belarus, the two regimes are not fully symmetrical. Certain exemptions and derogations may differ, and specific activities may be subject to authorization requirements under the Belarus ordinance that do not apply in the same manner under the UKRO, or vice versa.

Financial institutions should therefore consult the Belarus ordinance directly and not assume that the scope of restrictions and exceptions is identical in all respects.

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 has already adopted a 21^st sanctions package, and is discussing a 22^nd, which is touted as the bloc’s largest since 2022, so that further alignment measures by Switzerland will be expected.

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

UKRO, as of 20 August 2026

• Official publication:
  • UKRO German version
  • UKRO French version
  • Unofficial English translation
  • Redline against the version of 26 February 2026 (English)

SECO FAQ, as amended on 30 June 2026

• Official publication:
  • German version
  • French version
  • Unofficial English translation

• 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.