On 16 August 2023, the Swiss Federal Council decided to implement further sanctions against Russia and to implement the 11th Sanctions package to the European Union. Accordingly, the Swiss Ordinance on Measures in Connection with the Situation in Ukraine has been updated. The new measures entered into force on 16 August 2023 at 6 p.m.

As part of the 11th sanctions package dated 23 June 2023., the EU established the legal foundation for an instrument that is aimed to prevent sanctions from being avoided. This opens the possibility of prohibiting the export to third countries of dual-use goods, which are items that can be utilised for both civilian and military purposes, as well as goods that are intended to strengthen Russia’s military and technological capabilities. This package of EU sanctions is primarily geared towards effectively preventing and combating circumvention in third countries and by third countries. However, the EU intends to use this instrument in the future only as a very last resort. At this point, it does not have any significant impact.

Combating circumvention of sanctions against Russia in third countries is also the primary focus of the new measures introduced in Switzerland. As of the 28 June 2023, the Swiss Department of Economic Affairs, Education and Research (EAER) had already sanctioned more than one hundred additional people and organisations that fell under its jurisdiction.

More recently, as of 16 August 2023, the Federal Council has approved all the remaining sanctions that were included in the 11th sanctions package of the EU that were applicable to Switzerland. Among these measures is the extension of the ban on the export of goods with dual uses as well as goods for the purpose of enhancing Russia’s military and technological capabilities to additional 87 companies. Companies from other countries that have supplied Russia with the aforementioned goods are included in this category. In addition, the list of items that are prohibited from being exported has been expanded to include items like electronic components and the ingredients needed to make chemical weapons. It is no longer permissible to sell intellectual property rights or trade secrets to Russian companies in connection with the sale of a variety of goods. This is done with the intention of preventing goods from being manufactured in Russia that cannot be delivered to Russia for some reason. The prohibition on passing goods through Russia has been expanded to include additional items, such as jet fuels and fuel additives, as well as items that are suitable for use in the aerospace industry.

In the area of finance, the existing ban on selling securities denominated in Swiss francs or in an official currency of an EU member state to individuals or organisations based in Russia was expanded. Previously, this ban only applied to sales of securities denominated in Swiss francs. Regardless of the type of currency being used, it is now prohibited to sell securities to individuals or organisations located in Russia.