Sanctions 2026

SWITZERLAND Law and Practice Contributed by: Philippe M. Reich, Kaspar Projer, Samantha Salsench and Anna Zellweger, Baker McKenzie Switzerland AG

Ordinance, the Swiss Ordinance on Measures against Belarus or the Swiss Ordinance on Measures against the Islamic Republic of Iran. By way of example, Article 11a paragraph 1 of the Ukraine Ordinance prohibits the sale, supply, export, etc, to or for use in the Russian Federation of goods for the strengthening of the industry. Under certain circumstances, in case a licensing ground is present, SECO may grant an exemption – eg, if a specific activ - ity (such as the sale of restricted goods) is necessary for medical or pharmaceutical purposes with non- military end use (see Article 11a paragraph 4 of the Ukraine Ordinance). Furthermore, Article 30a of the Ukraine Ordinance provides for licensing grounds for the sale, supply, etc, of certain restricted goods until 31 December 2026, where such sale, supply, etc, is strictly necessary for the divestment from Russia or the termination of busi- ness activities in Russia, provided certain cumulative conditions are fulfilled. In a similar vein, SECO may grant a licence for services or software banned under Article 28e of the Ukraine Ordinance until 31 Decem - ber 2026, provided certain cumulative conditions are fulfilled. Further details can be found in the section on “Seco’s Approach Towards Exit Licences” of the Switzerland Trends and Developments chapter in this guide. 2.3.2 Provision of Legal Services The concept of a “general licence” does not exist under Swiss sanctions. Instead, licences are granted on an individual basis only. For instance, Article 15 paragraph 5 letter b of the Ukraine Ordinance provides an exceptional licensing ground for payments from frozen accounts of desig - nated persons for the fulfilment of contracts – eg, for legal services. More specifically, Article 28e paragraph 1 letter a of the Ukraine Ordinance prohibits the direct or indirect provision of legal services to the Government of the Russian Federation, or to legal entities, companies or organisations established in the Russian Federa - tion, Crimea, Sevastopol or the areas of the Donetsk, Luhansk, Kherson and Zaporizhzhia Oblasts that are

not controlled by the Ukrainian government. Accord - ing to Article 28e paragraph 8 of the Ukraine Ordi - nance, these prohibitions do not apply to services and software intended for the exclusive use of Rus - sian entities owned or controlled by Swiss, EEA or partner country entities, nor to services provided in connection with humanitarian activities carried out by public authorities or publicly funded organisations. According to Article 28e paragraphs 12 et seqq. of the Ukraine Ordinance, SECO may grant a licence if certain conditions are met. 2.4 Reporting There are numerous reporting obligations under Swiss sanctions laws. In principle, under the current SECO guidance (“SECO FAQ”, version of 30 June 2026 – eg, questions 2.9.6 and 2.17.4), such reports must be submitted to SECO by the individuals or companies concerned (or their legal counsel based on a power of attorney), usually via electronic means such as file transfer or by email. In particular, within the scope of financial sanctions, various reporting obligations must be observed. One of the most important reporting duties can be found in Article 16 of the Ukraine Ordinance, whereby com - panies and individuals who hold or manage assets owned or controlled by designated individuals or enti - ties, or who have knowledge of the existence of such assets, are obliged to notify SECO immediately of all transactions which occurred in the two weeks prior to the listing of these persons, companies or organi - sations. Further details can be found in the section on “Trends in the financial sector” of the Switzerland Trends and Developments chapter in this guide. Other reporting obligations (or notification obligations, as they are usually referred to) can for instance be found in Article 28e paragraph 6 of the Ukraine Ordi - nance – ie, the notification of ongoing services or soft - ware still being provided to Russian group companies held by Western parent companies. Finally, reporting obligations are also commonly attached to licensed activities, requiring companies to notify SECO on a regular basis of the execution of transactions (eg, exports or sales) carried out under granted licences.

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