Switzerland adopts remaining tranche of EU 18th sanctions package against Russia + parallel Belarus alignment

Mechanism

Switzerland is not an EU member but has followed the EU Russia-sanctions regime package-by-package since the Federal Council's 28 February 2022 decision to mirror EU measures under the Embargo Act (EmbA), implemented through recurring amendments to the Ukraine Ordinance (SR 946.231.176.72). The EU adopted its 18th package on 18 July 2025 (Council Regulation (EU) 2025/1494); the WBF (Federal Department of Economic Affairs, Education and Research) took over the elements within its own competence on 12 August 2025, and the 29 October 2025 Federal Council decision (AS 2025 662) closes the remaining goods/finance/ services gap.

Global Trade Alert logs this single Swiss ordinance amendment as four separate interventions by measure type: (1) controls on commercial transactions and investment instruments targeting financial services and investment banking; (2) an import ban touching petroleum oils and waste/scrap goods; (3) an export ban touching structural-metal products, general-purpose machinery and machine-tools; and (4) a second commercial-transactions/investment-instruments control touching crude petroleum trade and motor-vehicle/trailer goods. All four stem from the same 29 October 2025 Bundesrat decision and effective date, so they are filed here as one action.

Downstream implications

• Swiss trading/finance hub: further narrows the channel for Geneva/Zug

commodity traders and Swiss banks to intermediate Russia-linked petroleum, metals-machinery and motor-vehicle trade or provide investment-banking services to sanctioned counterparties.

• Sets up 19th/20th package catch-up: the EU had already moved to its 19th

package (Council Regulation (EU) 2025/2033, 23 October 2025) six days before this Swiss decision — Switzerland's package-by-package cadence means it was still closing the 18th-package gap as the EU's 19th package took effect, consistent with the lag later closed by the 12 December 2025 and 25 February 2026 Swiss actions already on file.

• Asset-freeze annex growth: 14 individuals and 41 companies/organizations

added to the freeze list in the same decision, continuing the incremental expansion pattern tracked across prior Swiss sanctions filings.

Open questions

• Full text/annex detail of the specific HS/goods codes added to the export

and import bans (Fedlex PDF is in German; a full annex-level breakdown was not extracted in this filing).

• Whether SECO published a parallel guidance note on the crude-petroleum and

motor-vehicle transaction controls comparable to its dual-use circumvention guidance for earlier packages.