Switzerland Total-Revises Ukraine Ordinance: Bans All Dual-Use Exports, Adds Aviation, Space and Oil-Refining Controls on Russia

Mechanism

Switzerland is not an EU member but has autonomously aligned its Russia sanctions regime with the EU's since the 2014 Crimea annexation. Following Russia's full-scale invasion of Ukraine on 24 February 2022, the Federal Council decided on 28 February 2022 to adopt the EU's sanctions packages of 23 and 25 February 2022, and gave that decision legal effect on 4 March 2022 through a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), entering into force the same day at 18:00. The revised ordinance extends the export ban to all dual-use goods regardless of end use or end user (removing case-by-case licensing discretion), bans goods that could strengthen Russia's military, technological, defence or security capacity, and adds sector-specific bans on goods and services for the oil sector, aviation, space, and oil refining/gas liquefaction.

Downstream implications

• Swiss exporters of dual-use goods (electronics, machine tools,

navigation/sensor components) to Russia lose the prior case-by-case licensing route entirely — the ban is now categorical.

• Swiss aerospace and oil/gas-equipment suppliers with Russian customers or

distributors are cut off, mirroring the EU's parallel measures.

Open questions

• Full enumerated goods lists (dual-use Annex I items, oil-sector

equipment list) are set out in Annexes to SR 946.231.176.72 not reproduced in the press release; a later filing should confirm annex content against the EU's Regulation (EU) 2022/328 and 2022/330 if granular HS-code coverage is needed.