Switzerland: SECO amends Ukraine Ordinance to align with EU 13th Russia sanctions package

Mechanism

Switzerland does not automatically adopt EU sanctions; each EU package requires a separate Federal Council/WBF amendment to the Ukraine Ordinance (SR 946.231.176.72). This tranche brought Swiss measures into line with the EU's 13th package (adopted around the two-year mark of the full-scale invasion): expanding the asset-freeze/designation list to over 100 individuals and nearly 90 entities tied to the Russian military-industrial complex and to DPRK-Russia arms supply, and widening the dual-use/military-technology export ban to 27 additional companies assessed as circumvention conduits for goods and technology restricted under earlier packages.

Severity basis

The amendment designates over 100 individuals and nearly 90 entities in a single tranche and extends the dual-use export ban to 27 additional companies — a numerically disclosed expansion of an existing restrictive regime, directly comparable to the 11th-package tranche (12 individuals / 87 entities) already in the register at the same severity.

Downstream implications

• Swiss-domiciled exporters and financial institutions must screen counterparties

against the expanded designation list and the widened export-ban company list.

• The 27 newly listed export-ban companies close a circumvention route for

dual-use/military-technology goods that earlier Swiss-EU alignment tranches had not yet reached.

Open questions

• Full identities of the 27 newly listed export-ban companies and whether any

are Swiss-domiciled intermediaries, as opposed to third-country entities.