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2023-01-25-switzerland-seco-russia-ordinance-9th-eu-package-mining-investment-ban [3]Policy↑ Trade↓ Market— single typed policy action — the spine's centre of gravity Switzerland: Ninth EU Sanctions Package Alignment — Russian Mining Investment Ban, Export Control Expansion
Sanction↓ Restrictive~🇨🇭 CH · Federal Council / State Secretariat for Economic Affairs (SECO)✎ 2026-10-01
announced 25 Jan 2023
effective 25 Jan 2023
Status
effective 25 Jan 2023 · stage not filed
Sourcing
🟢 primary-OJ 1 primary
🇨🇭 CH issued this sanction measure targeting 1 jurisdiction, touching mining, aerospace, dual-use-technology and 1 more sectors. It reads as restrictive.
RBI 2quant 2 · $3B📌 stable
Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the EU's ninth sanctions package, effective 6pm on 25 January 2023. The amendment bans new Swiss investment, equity provision, and participation (including joint ventures) in Russian mining-sector entities, with a carve-out for critical raw materials (aluminium/bauxite, chromium, cobalt, copper, iron ore, mineral fertilisers, molybdenum, nickel, palladium, rhodium, scandium, titanium, vanadium). It also extends export bans on aerospace goods to aircraft and drone engines, adds new controls on dual-use and military/security-enhancement goods, bans product testing/advertising/market-research services to Russia, and designates roughly 200 additional individuals and entities, including the Russian Regional Development Bank, to frozen-asset lists.
Analyst notesShowHide
Mechanism
Switzerland's sanctions regime against Russia operates by Federal Council ordinance amendment under the Embargo Act, tracking the EU's sequential sanctions packages with a lag (here, the EU's ninth package of 16 December 2022 took effect in Switzerland on 25 January 2023). The operative new restriction for the economic-exposure product is the mining-investment ban: Swiss persons/entities may not acquire or extend participation, provide equity, or form joint ventures with entities operating in the Russian mining sector, except where the activity concerns the twelve critical raw materials listed in Annex 30. The carve-out means Swiss trading houses and commodity financiers retain a lawful channel into Russian-origin critical minerals even as the broader mining-investment door closes — a structurally important asymmetry for any company with Swiss-domiciled commodity-trading exposure.
Severity basis
quant: the press release discloses a concrete count — approximately 200 additional individuals and entities added to the Swiss sanctions list — in addition to the sector-wide investment ban and export-control expansion. Severity of 3 reflects a sanctions-alignment/enforcement action (extending an existing regime) rather than a first-instance embargo.
Downstream implications
- Swiss-domiciled commodity traders and mining financiers lose the ability to
acquire or extend stakes in Russian mining operations outside the Annex 30 critical-raw-materials carve-out.
- The critical-raw-materials exemption preserves a lawful Swiss channel for
Russian-origin aluminium, cobalt, nickel, titanium, and vanadium investment — relevant to any company sourcing these materials via Swiss trading intermediaries.
- Aerospace export-control extension to aircraft/drone engines adds a further
licensing chokepoint for Swiss suppliers into Russian aviation and UAV supply chains.
Open questions
- Whether any Swiss mining-sector investment was divested or restructured as
a direct result of this ordinance amendment.
- Full list of the ~200 newly designated individuals/entities was not
reproduced in the primary press release; SECO's SESAM database would carry the complete designation list.