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12th Sanction package
Markus Pritzker
31 Jan 2024
12 min
On 31 January 2024, Switzerland aligned with the European Union's 12th package of sanctions against Russia, responding to the ongoing military aggression towards Ukraine. These sanctions, effective from 1 February, include a phased ban on Russian diamonds and import restrictions on goods benefiting Russia's revenue or military capabilities. Additionally, they impose financial restrictions on Russian control over Swiss crypto-asset service companies and enforce measures to support the oil price cap on Russian oil. The Swiss Federal Council is also considering further measures, such as a notification requirement for fund transfers, to enhance the effectiveness of these sanctions.
On 31 January 2024, Switzerland announced the implementation of additional sanctions against Russia, aligning itself with the European Union's (EU) 12th package of sanctions. This decision by the Federal Council is a response to Russia's continued military aggression towards Ukraine. The sanctions, set to take effect from 1 February, signify Switzerland's commitment to joining the EU's efforts, which had already expanded its sanctions in December 2023. Notably, on 21 December, Switzerland had extended its sanctions list to include 147 more individuals and entities.
The EU's 12th sanctions package, adopted on 18 December 2023, was designed to strengthen the enforcement of existing sanctions against Russia and to prevent their circumvention. It introduced several new sanctions aimed at further undermining Russia's destabilizing activities against Ukraine's territorial integrity, sovereignty, and security. Following the EU's lead, the Swiss Federal Department of Economic Affairs, Education and Research (EAER) expanded its sanctions list to include an additional 147 individuals and entities on 22 December. To date, Switzerland has sanctioned 1,422 individuals and 291 organizations and entities as part of its efforts to address Russia's actions in Ukraine. On the last day of January, the Federal Council decided to adopt the remaining measures of the EU's 12th sanctions package that are applicable to Switzerland, aiming to enhance their impact.
Among the notable new sanctions is a phased ban on the purchase and import of Russian diamonds, reflecting Switzerland's participation in the G7 summit's decision on 6 December 2023 to cut off a significant revenue source for Russia. Swiss authorities are coordinating internationally to ensure these restrictions are implemented effectively.
Additionally, Switzerland has introduced bans on importing certain goods from Russia that contribute significantly to its state revenue. This includes items such as pig iron and liquefied petroleum gas (LPG). The sanctions also extend to goods that could bolster Russia's military and technological advancement or support its industrial sector, including the export and sale to Russia of specific chemicals, lithium batteries, certain drone motors, as well as machine tools and parts. More entities have been added to the list of companies facing restrictions on trading dual-use goods.
In the financial sector, new regulations prevent Russian nationals and residents from controlling Swiss companies that offer crypto-asset services. Measures have been put in place to ensure the enforcement of the oil price cap on Russian crude oil and petroleum products, including mandatory exchange of price information among market participants and with authorities. There are also new requirements for reporting and authorizing the sale of tankers that could be used to bypass the oil price cap.
In the services sector, the provision of software for enterprise management and industrial design and manufacture to Russian companies is now banned. However, the Federal Council has allowed exceptions for Swiss companies' Russian subsidiaries.
The Federal Council is also considering further measures, such as a requirement for notification when transferring funds out of the EU by companies controlled by Russians or entities based in Russia. For now, the requirement has not been implemented; instead, the EAER, in collaboration with the Federal Department of Finance, is tasked with assessing the potential introduction and structure of such a requirement in Switzerland, particularly its application to transfers to third countries, to maximize the effectiveness of sanctions enforcement.
On 31 January 2024, Switzerland announced the implementation of additional sanctions against Russia, aligning itself with the European Union's (EU) 12th package of sanctions. This decision by the Federal Council is a response to Russia's continued military aggression towards Ukraine. The sanctions, set to take effect from 1 February, signify Switzerland's commitment to joining the EU's efforts, which had already expanded its sanctions in December 2023. Notably, on 21 December, Switzerland had extended its sanctions list to include 147 more individuals and entities.
The EU's 12th sanctions package, adopted on 18 December 2023, was designed to strengthen the enforcement of existing sanctions against Russia and to prevent their circumvention. It introduced several new sanctions aimed at further undermining Russia's destabilizing activities against Ukraine's territorial integrity, sovereignty, and security. Following the EU's lead, the Swiss Federal Department of Economic Affairs, Education and Research (EAER) expanded its sanctions list to include an additional 147 individuals and entities on 22 December. To date, Switzerland has sanctioned 1,422 individuals and 291 organizations and entities as part of its efforts to address Russia's actions in Ukraine. On the last day of January, the Federal Council decided to adopt the remaining measures of the EU's 12th sanctions package that are applicable to Switzerland, aiming to enhance their impact.
Among the notable new sanctions is a phased ban on the purchase and import of Russian diamonds, reflecting Switzerland's participation in the G7 summit's decision on 6 December 2023 to cut off a significant revenue source for Russia. Swiss authorities are coordinating internationally to ensure these restrictions are implemented effectively.
Additionally, Switzerland has introduced bans on importing certain goods from Russia that contribute significantly to its state revenue. This includes items such as pig iron and liquefied petroleum gas (LPG). The sanctions also extend to goods that could bolster Russia's military and technological advancement or support its industrial sector, including the export and sale to Russia of specific chemicals, lithium batteries, certain drone motors, as well as machine tools and parts. More entities have been added to the list of companies facing restrictions on trading dual-use goods.
In the financial sector, new regulations prevent Russian nationals and residents from controlling Swiss companies that offer crypto-asset services. Measures have been put in place to ensure the enforcement of the oil price cap on Russian crude oil and petroleum products, including mandatory exchange of price information among market participants and with authorities. There are also new requirements for reporting and authorizing the sale of tankers that could be used to bypass the oil price cap.
In the services sector, the provision of software for enterprise management and industrial design and manufacture to Russian companies is now banned. However, the Federal Council has allowed exceptions for Swiss companies' Russian subsidiaries.
The Federal Council is also considering further measures, such as a requirement for notification when transferring funds out of the EU by companies controlled by Russians or entities based in Russia. For now, the requirement has not been implemented; instead, the EAER, in collaboration with the Federal Department of Finance, is tasked with assessing the potential introduction and structure of such a requirement in Switzerland, particularly its application to transfers to third countries, to maximize the effectiveness of sanctions enforcement.