SWITZERLAND Law and Practice Contributed by: Philippe M. Reich, Kaspar Projer, Samantha Salsench and Anna Zellweger, Baker McKenzie Switzerland AG
The challenge for many companies is to understand new sanctions measures, navigate increasing diver - gences across regimes, and implement the necessary changes to their businesses in an informed manner – particularly for companies operating across multiple jurisdictions. Many companies are also wrestling with whether to maintain business operations in or ties with Russia or to exit the market entirely. While sanctions regimes continue to permit divestments and such steps are generally supported from an EU and Swiss policy per - spective, this decision-making process is increasingly shaped by risks arising from Russian countermeas - ures. In particular, there is a growing risk of assets being placed under so-called temporary administra - tion or even full nationalisation, which is now being seen with increasing frequency. The latest EU measures place a clear emphasis on anti-circumvention. The EU’s “anti circumvention tool” – targeting exports of specified items to certain third countries to prevent onward supply to Russia – has been activated for the first time, in relation to Kyr - gyzstan. Switzerland has not yet introduced a compa - rable mechanism, although some form of action may be expected to avoid circumvention risks. There is also an increased focus on third-country des - ignations. Recent EU packages – largely mirrored by Switzerland – target companies in jurisdictions such as China and India deemed to support Russia’s war efforts, adding further complexity for businesses across their supply chains. At the same time, Swit - zerland has taken a more selective approach, nota - bly under the 20th package, by not listing certain EU designated third-country entities, in particular Chinese companies. A further key development is the introduction of tar - geted restrictions relating to Russian special economic zones (SEZs), which have had a significant impact on business activities connected to Russia. The breadth of these measures – covering investments, contrac - tual relationships and financing arrangements – mate - rially limits companies’ ability to maintain or develop ties with entities operating in such zones.
There is also a continued expansion of services and software restrictions as a key area of focus. Recent measures reflect an increasing effort to restrict access to high-value technical, digital and intellectual inputs, coupled with broader authorisation requirements. This underscores a wider shift towards targeting non goods-based contributions to the Russian economy and further adds to the compliance burden for com - panies. Finally, taking a broader view on Swiss sanctions pol - icy, Switzerland has, in line with wider international developments, recently adjusted its approach across different sanctions regimes. On the one hand, sanc - tions against Syria were significantly eased as of 20 June 2025, with measures now more narrowly target - ed at specific actors and sectors. On the other hand, sanctions against Iran were materially expanded on 12 December 2025, including the reintroduction of a range of trade-related and financial restrictions, as well as funds transfer controls. Neither the State Secretariat for Economic Affairs (SECO) nor the European Commission have issued comprehensive guidance on due diligence and com - pliance standards. Companies must therefore apply a risk-based approach, calibrating measures to their risk profile, including robust screening systems and regular counterparty (including payment providers) checks against relevant sanctions lists. Companies must also ensure that their internal com - pliance frameworks are adequately resourced and structured to manage sanctions risks effectively. Against this backdrop, they may consider limiting transactional activity involving counterparties with a Russia or Belarus nexus and refraining from expand - Sanctions have an impact on almost all relevant sec - tors of the Swiss economy. The Swiss industrial and financial sectors, but also the trading, energy as well as healthcare, luxury and consumer goods sectors, have been particularly affected. Switzerland’s pragmatic implementation of EU sanc - tions measures in the Swiss Ordinance on measures ing such business ties. 1.3 Key Industries
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