Switzerland: SECO amends Ukraine Ordinance to align with EU 11th Russia sanctions package

Mechanism

Switzerland does not automatically adopt EU sanctions; each EU package requires a separate Federal Council amendment to the Ukraine Ordinance. This tranche brought Swiss measures into line with the EU's 11th package: closing a dual-use export-ban exemption route via two UAE intermediary firms, tightening the existing securities-sale restriction to a fixed issuance-date cutoff (6 August 2023) applied currency-agnostically, and expanding the asset-freeze list.

Severity basis

The amendment adds 12 individuals and 87 entities to the Swiss asset-freeze list in a single tranche and closes a UAE-routed exemption to the dual-use export ban — a material, numerically disclosed expansion of an existing restrictive regime.

Downstream implications

• Swiss-domiciled financial institutions must screen against the expanded

asset-freeze list and the new securities issuance-date cutoff.

• Exporters of dual-use goods lose the exemption route via the two newly listed

UAE intermediary firms.

Open questions

• Whether the Druzhba-style carve-outs or exemptions present in the EU 11th

package were mirrored identically in the Swiss text, or narrowed further.