Switzerland continues aligning its sanctions regime to the European Union (EU) sanctions against Russia. On 29 February 2024, the Federal Department of Economic Affairs, Education and Research (DEFR) adopted further measures against Russia, in line with the 13th sanctions package adopted by the EU. Alongside, the State Secretariat for Economic Affairs (SECO) has updated its FAQ document, providing further clarifications notably on the asset freeze and contractual obligations aimed at preventing re-exportation to Russia
Introduction
On 29 February 2024, the DEFR adopted further sanctions against Russia with a view to mirroring the latest measures imposed by the EU on 23 February 2024. The corresponding amendments to the Ordinance on measures in connection with the situation in Ukraine (“UKRO“) entered into force on 1 March 2024, at 18:00 CET.
An unofficial English translation of UKRO as of 20 March 2024[1] and a redline against the version of 1 February 2024 are available, respectively here and here.
Also, on 29 February 2024, the State Secretariat for Economic Affairs (SECO) published an amended version of its clarifications in the form of “frequently asked questions” (FAQ) document, inter alia to include frequently asked questions in relation to Article 14f UKRO.
An unofficial English translation of the FAQ as of 29 February 2024, 11 March 2024 and a redline against the version of 29 February 2024 are available, respectively here, here and here.
[1] The version as of 20 March 2024 is already available and reflects the restrictions that will enter into force on 20 March 2024, in particular Articles 14e (4) and 14f UKRO.
