Swiss sanctions against Russia – Further alignment with the EU – Implementation of the 21st Sanctions Package

On 4 November 2026, the Swiss Federal Council adopted further sanctions against Russia with a view to mirroring the measures adopted by the EU on 23 July 2026 as part of its 21^st sanctions package. The corresponding amendments to the Ordinance on measures in connection with the situation in Ukraine (“UKRO”) entered into force on 5 November 2026, with the exception of the revised Article 12h UKRO (LNG terminals), which will enter into force on 1 January 2027.

The Federal Department of Economic Affairs, Education and Research (“EAER”) had already amended the Swiss sanctions lists on 3 November 2026, with effect from 4 November 2026. In parallel, the Federal Council also adopted the new EU measures against Belarus (see section 5 below).

1. Unofficial translation into English of the UKRO as of 5 November 2026 and a redline against the version of 20 August 2026 are available here and here, respectively

The newly adopted amendments concern the sanctions lists, trade restrictions, the energy sector, the financial sector (including crypto-assets) and the legal protection of Swiss persons and companies. The following highlights some of the most relevant amendments:

• Sanctions lists – New listings and delistings (Annexes 2, 8, 14, 14a, 15b, 15c and 33 UKRO)

The EAER took over a large part of the new EU listings, adding individuals, companies and entities to Annex 8 UKRO (asset freeze and, for individuals, entry and transit ban; Articles 15 and 29 UKRO); companies, some located in third countries, to Annex 2 UKRO (end-users subject to export restrictions; Articles 4 to 6 UKRO); Russian and third-country banks, financial institutions, crypto-asset service providers and third-country companies to the transaction prohibitions (Annexes 14, 14a and 15b; Articles 24c, 27 and 27a UKRO); Russian airports and ports to Annex 15c UKRO (Article 24d UKRO); and vessels' to Annex 33 UKRO (Article 12d UKRO). 

In line with the corresponding EU decision, 6 individuals and 1 company have been removed from Annex 8 UKRO. The asset freeze and the prohibition to make funds or economic resources available based on their former listing no longer apply. However, financial intermediaries should still verify whether other restrictions apply (e.g. ownership or control by another listed person) and remain bound by their obligations under the Swiss anti-money laundering framework.

Following a weighing of legal and foreign policy interests, Switzerland decided not to list, for the time being, 2 Russian nationals designated by the EU, nor to add 14 third-country companies to Annex 2 UKRO, considering that the operational measures introduced with the 20^th package already prevent the circumvention of trade restrictions.

• Transaction prohibitions – Three-month derogations for closing accounts (Articles 24c, 27 and 30cter UKRO)

SECO may, after consulting the competent services of the Federal Department of Foreign Affairs (“FDFA”) and of the Federal Department of Finance (“FDF”), authorise, for a maximum of three months, transactions necessary to withdraw assets from, or close accounts held with, banks, companies or entities listed in Annexes 14, 14a or 15b UKRO since 4 November 2026 (Articles 24c(3), 27(4) and 30cter(2) UKRO), provided that:

• the accounts are held or controlled by Swiss or EEA nationals or by natural persons holding a temporary or permanent residence permit in Switzerland or in an EEA member state;
• the transaction is necessary to terminate the activities with the listed banks, companies or entities or the contracts or other agreements concluded with them; and
• the assets are transferred to a financial institution established or incorporated under Swiss or EEA law, or to a third-country financial institution owned or controlled by such a financial institution.

Note: Requests for such derogations must be filed with SECO within three months of the listing of the relevant bank, company or entity (Articles 24c(4), 27(5) and 30cter(3) UKRO).

• Asset freeze – New derogation for compensation and insurance payments by shadow-fleet operators (Article 15(9duodecies) UKRO)

SECO may exceptionally release frozen assets of listed persons that own, control, manage or operate “shadow fleet” vessels (or support their operations), where needed to pay compensation or an insurance benefit for a risk for which they are liable. The payment must go to non-listed companies established in Switzerland, the EEA or a partner state, to nationals of these states, or to holders of a residence permit in one of them.

• Energy – LNG and Sakhalin-2 (Articles 12e, 12g and 12h UKRO; Annexes 29 and 29a)

Any transfer of an LNG carrier to a third country must now be notified to SECO without delay, as is already the case for tankers (Article 12e(4) UKRO).

A new exemption allows the purchase or transport of LNG destined for states outside Switzerland and the EEA under contracts concluded before 24 February 2022, with a duration of more than one year and not significantly amended since that date, up to the volume transported under such contracts in 2025. Persons relying on it must report their 2025 volumes to SECO by 7 December 2026 and provide per-delivery information by the same date and every three months thereafter (Article 12g(4) - (6) UKRO).

A further new exemption covers LNG from the Sakhalin-2 project destined for Japan and South Korea until 31 March 2028 (Article 12g(3) UKRO; Annex 29a), and the existing derogation for Sakhalin-2 crude oil blended with condensates destined for Japan is extended to the same date (Article 12b UKRO; Annex 29).

From 1 January 2027, the revised Article 12h UKRO will prohibit the provision of LNG terminal services to persons, entities or bodies in Russia and to entities more than 50% owned or controlled by a Russian national or by a person or entity in Russia.

• Crypto-assets – Acquisition prohibition (Article 20(2bis)(a) UKRO)

Article 20(2bis)(a) UKRO now prohibits enabling Russian nationals or natural persons residing in Russia to acquire, directly or indirectly, a legal person, company or entity established or incorporated under Swiss or EEA law that provides crypto-asset services, irrespective of the nature of such services.

• Protection against abusive Russian court decisions and claims (Articles 28k, 29d, 30 and 30f UKRO; Annex 41)

The legal protection framework introduced in previous packages is further strengthened:

• Article 29d(1) UKRO: Decisions of Russian courts or authorities are not recognised, implemented or enforced where they (a) relate to a contract the performance of which has been prevented or affected, directly or indirectly, by measures imposed under the UKRO, the Ordinance of 27 August 2014 or the Ordinance of 2 April 2014 (or equivalent measures of an EEA member state), and (b) establish the direct or indirect liability of Swiss or EEA nationals, residents or established entities, recognise or enforce a claim against them, or otherwise give effect to such a claim, in particular in connection with insolvency, bankruptcy, composition or similar proceedings.
• Article 30 UKRO: The prohibition to satisfy claims now expressly covers contracts and transactions affected by the UKRO, the Ordinance of 27 August 2014 and the Ordinance of 2 April 2014. In any proceedings for the enforcement of a claim, the burden of proof that satisfying the claim is not prohibited lies with the person seeking enforcement.
• Article 30f UKRO: The right of Swiss nationals, residents and Swiss-established entities to claim damages (including legal costs) before Swiss courts is restated and extended. It covers (i) claims brought before courts outside Switzerland and the EEA by persons referred to in Article 30(1)(a) to (d) UKRO in connection with sanctions-affected contracts or transactions, and third-country (non-Russian) decisions enforcing such claims, and (ii) decisions taken under Russian Presidential Decree No. 302 of 25 April 2023 (as amended) or related Russian legislation that are unlawful under customary international law or the 1990 Switzerland – USSR investment protection agreement, and third-country decisions enforcing them. Such claims are only available where no effective remedy exists before the competent jurisdiction.

• Wind-down derogations extended until 31 December 2027 (Articles 30a, 30b, 30c, 30cbis and 35(17)(b) UKRO)

To allow for the orderly winding down of activities in Russia, the following derogations are extended until 31 December 2027:

• Article 30a UKRO: derogations for the sale, supply, transit or transport of certain goods and related IP rights or trade secrets (including for the divestment of joint ventures), and for the import of certain goods;
• Article 30b UKRO: derogations from the prohibition on transactions with state-owned companies (Article 24a(1) UKRO) for divestment or withdrawal from a Swiss or EEA entity;
• Article 30c UKRO: derogations from the prohibitions concerning services and software under Article 28e UKRO;
• Article 30cbis UKRO: derogations from the prohibition to satisfy certain claims, where necessary for divestment or the cessation of activities in Russia;
• Article 35(17)(b) UKRO: exemption from Article 24a(1) UKRO for transactions necessary for the liquidation of joint ventures established before 26 March 2022.

1. The persons and entity removed from Annex 8 UKRO with effect from 4 November 2026 are: Yuri Nikolaevich Shvytkin (SSID 175-48591), Alisher Burkhanovich Usmanov (SSID 175-50771), Mikhail Maratovich Fridman (SSID 175-50792), Ali Reza Tangsiri (SSID 175-64276), Andrey Pavlovich Falaleev (SSID 175-70223), Alexander Georgievich Leonov (SSID 175-72133) and Redbird Corporate Services Ltd (SSID 175-95503).

⁽³⁾ 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 listings and transaction prohibitions under Articles 24c, 27 and 27a UKRO, which require timely updates of screening tools and, where relevant, recourse to the three-month derogations for closing accounts;
• The prohibition under Article 20(2bis)(a) UKRO on enabling Russian nationals or residents to acquire Swiss or EEA crypto-asset service providers, in particular in M&A and corporate finance transactions;
• The LNG-related notification obligations and prohibitions under Articles 12e, 12g and 12h UKRO, in particular for financial institutions involved in trade finance, shipping or commodity trading;
• The import prohibition under Article 14c UKRO and the revised Annex 20, including the transitional period for pre-existing contracts;
• Claims brought by Russian counterparties, in light of the non-recognition of certain Russian decisions and the strengthened protection under Articles 29d, 30 and 30f UKRO;
• The continued relevance of FINMA supervisory expectations regarding sanctions compliance as part of organizational 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. 

On 4 November 2026, the Federal Council also decided to adopt the new measures adopted by the EU against Belarus on 23 July 2026, on the grounds that Belarus continues to take part in Russia's war against Ukraine. The amendments to the Belarus sanctions lists entered into force on 4 November 2026 at 11 p.m. and the sectoral measures on 5 November 2026. 

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.

Since the adoption of its 21^st package, the EU has continued to amend its sanctions lists, in particular on 12 October 2026. Further EU measures, including a possible 22^nd sanctions package, are expected, so that further alignment measures by Switzerland can 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 5 November 2026

• Official publication:

  • UKRO German version
  • UKRO French version
  • Unofficial English translation
  • Redline against the version of 21 September 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.