Switzerland aligns with EU's 12th Russia sanctions package (Ordinance on Measures Relating to the Situation in Ukraine, SR 946.231.176.72)

Mechanism

Switzerland is not an EU member but routinely aligns its autonomous Russia sanctions regime with the EU's, to avoid becoming a circumvention route for goods or financial flows the EU has just restricted. Following the EU's 12th sanctions package (Council Regulation (EU) 2023/2878, adopted 18 December 2023 — see 2023-12-18-eu-12th-sanctions-package-russia-diamond- import-ban), the Swiss Federal Council decided on 31 January 2024 to amend the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), with the change entering into force the same day at 18:00. The amendment pulls in the EU's expanded import-ban list (diamonds, steel and other revenue-generating products) and adds a Switzerland-specific financial-sector measure: a prohibition on Russian nationals or Russia-resident persons controlling Swiss companies that provide crypto-asset services, closing a route the EU package did not directly address for the Swiss financial center.

Downstream implications

• Swiss-domiciled crypto-asset service providers with Russian beneficial

owners or controllers fall directly in scope of the new control prohibition and must report affected relationships to SECO.

• Because Switzerland is a significant diamond-trading and refining hub

(alongside its precious-metals refining sector), alignment on the EU diamond restrictions closes an adjacent circumvention path the EU measure alone would not reach.

Open questions

• Whether any Swiss crypto-asset providers were found to be

Russian-controlled and required to unwind that control under the new prohibition.