On 19 August 2026, the Swiss Federal Council resolved to adopt the additional measures set out in the EU’s 20th sanctions package against Russia, consistent with its established practice of aligning with EU sanctions. Switzerland, however, will be constitutionally prohibited from implementing non-military coercive measures if the Neutrality Initiative is approved on 27 September 2026. This approval would mean Switzerland can no longer implement autonomous or EU sanctions except for those mandated by the UN Security Council.
In the meantime, this new package amending the Ordinance of 4 March 2022 on measures relating to the situation in Ukraine entered into force on 20 August 2026. Switzerland had already designated 115 individuals and entities for inclusion on its sanctions list on 22 May 2026 to align with EU designations adopted in April 2026. This list covered Russian ports Murmansk and Tuapse and the third-country port of Karimun Oil Terminal in Indonesia. Approximately 2,790 individuals and organisations are currently subject to asset freezes in Switzerland in connection with the war in Ukraine.
The new restrictive measures adopted by the Swiss Federal Council focus on energy, trade and financial sectors. These include a legal protection for Swiss operators modelled on the EU’s framework, and an extension of the existing ban on accepting grants from the Russian government to include companies in the research and innovation sector, and in research and educational institutions.
Energy measures
The Federal Council has issued new service bans in the energy sector, including maintenance, financial services, brokerage services and technical assistance relating to liquefied natural gas (LNG) tankers and icebreakers, and LNG terminals in Russia. Additionally, the sale of tankers to Russia is now prohibited.
Contracts for selling tankers to third countries must include a "no Russia clause" to prevent the subsequent resale or transfer of these tankers to the Russian Federation or for use in the Russian Federation. The sale and any other transfer of ownership of tankers destined for a third country must be reported to the State Secretariat for Economic Affairs (SECO).
Trade measures
Additional restrictions and prohibitions on exports and imports, designed to further undermine and erode Russia's military-industrial complex have been introduced.
These measures cover new export bans to Russia on goods, including goods from rubber to tractors and on items and technologies, such as additives for lubricants or laboratory glassware and new import ban on new metals, chemicals and minerals considered as economically significant goods generating substantial revenue for Russia.
Following the EU's approach, Switzerland has activated its anti-circumvention mechanism targeting exporters in third countries that re-export sanctioned EU goods to Russia. At present, the mechanism applies solely to the Kyrgyz Republic.
Financial measures
Financial measures prohibit direct or indirect participation in any transaction or technical development involving crypto-assets or central bank digital currencies (CBDC) designated in the Ordinance (i.e. A7A5 and RUBx) that are stablecoin pegged to the RUB as well as the digital CBDC RUB now being designed by the Central Bank of Russia.
Legal entities and individuals, including financial institutions, are prohibited from participating, either directly or indirectly, in any transaction involving legal entities, organisations or platforms established in the Russian Federation that provide services relating to crypto-assets or facilitate the exchange or transfer of crypto-assets.
These measures are intended to prevent Russia from using alternative means of payment to circumvent sanctions. According to the EU commission summary of this package, these measures are a total sectorial ban covering not only exchanges with Russian crypto asset service providers but any decentralised exchange platforms (DEX) enabling crypto trading. Even if the press release of the Swiss Federal Council did not contain explicit reference to DEX, alignment with EU interpretation seems reasonable and in line with public statements of the Swiss Government. Based on the wording of the Ordinance, however, it is unclear to what extent this reference to DEX is technically correct, given that references to organisations or platforms are tied to a Russian location. By design, an authentic DEX is absent from such a location. The prohibition of transactions involving designated crypto-assets would also affect transactions entered via a DEX.
Legal protection of Swiss operators
This mechanism allows protected persons (i.e. Swiss nationals, natural persons resident in Switzerland, and legal persons, entities and organisations established in Switzerland) to bring proceedings before the Swiss courts to obtain compensation for direct or indirect losses suffered as a result of claims or judgments outside Switzerland and the EEA by persons referred to in Article 30 of the Ordinance where the performance of a contract has been prevented by Swiss sanctions measures relating to the situation in Ukraine. A similar right exists for the protected persons where the damage results from decisions taken pursuant to Russian Decree No. 302 of 25 April 2023 or equivalent Russian legislation, provided that such decisions are contrary to customary international law or the 1990 Swiss-Soviet bilateral agreement on the protection of investments. In both cases, the claimant must demonstrate there is no effective remedy before the competent court.
Damages may be recovered from the persons referred to in Article 30 of the Ordinance who have benefited from or are responsible for the Russian decisions in question, from those seeking to enforce them in third countries (outside Russia) and from any person holding or controlling such entities, excluding lawyers and members of the judiciary.
If no forum is provided for by other provisions of Swiss law, proceedings may be brought before a Swiss court in a jurisdiction that has sufficient connection with the case.
Outlook
Switzerland has now formally implemented the remaining substantive measures of the EU's 20th package. Since Switzerland typically tracks EU restrictive measures in line with its established practice, further amendments of the Ordinance adopting the forthcoming EU forthcoming packages are to be expected, subject to the rejection of the Neutrality Initiative.
For financial institutions, particularly those active in trade finance, the persistent amendments and increased restrictions present challenges from the standpoint of compliance and the relationships with the relevant authorities since regulatory scrutiny is undeniable and shows no sign of stopping.
Finally, this package's focus on crypto-asset service providers should encourage these market participants to review their compliance framework.
For more information on these proposed regulations and Switzerland’s banking sector, contact your CMS client partner or the CMS experts who wrote this article.
