On 12 November, Switzerland expanded its regime of measures aimed at preventing the circumvention of international sanctions imposed in response to the ongoing situation in Ukraine.  The Federal Council’s Ordinance of 27 August 2014 was amended to take account of the EU’s September round of Russia related sanctions (see our Client Update of 15 September 2014) and expand restrictions in financial activities with Russian entities and individuals.

In the field of finance, trade in new financial instruments with a maturity exceeding 30 days (previously: exceeding 90 days) issued by five Russian banks and six companies, and the granting of loans with a maturity exceeding 30 days to those five banks and six companies, have become subject to authorisation by the State Secretariat for Economic Affairs (SECO). Secondary trading in newly issued financial instruments from outside Switzerland and the EU with a maturity exceeding 30 days has become subject to a duty to notify SECO.  In addition, existing business dealings with 24 individuals and entities became subject to a duty to notify and new business relationships with those persons have been prohibited. A complete list of individuals and entities subject to the Swiss anti-circumvention measures can be found on SECO’s website.

The Amendment imposed additional export controls on military and dual use goods and increased reporting obligations on the provision of financial and technical services in connection with these goods, as well as regarding deep water oil exploration and shale oil projects.

Overview of the Amendment (in French) SECO Press Release