Aktualisierte Sanktionsmeldung: Russland

Key dates

January 29, 2026

– SECO publishes amended Annex 28 of the Sanctions Ordinance

February 1, 2026

– New oil price cap (USD 44.1) becomes effective and binding

Immediate Deadline

– Financial intermediaries must implement updated prohibitions and screening procedures

Suggested considerations

• *Implement price cap enforcement: Update transaction monitoring systems to flag and block crude oil transactions exceeding USD 44.1 per barrel from Russian sources
• *Asset freezing: Continue blocking assets of sanctioned persons and entities; verify no new transactions circumvent the lower threshold
• *Reporting obligations: Report affected business relationships to SECO in accordance with the Sanctions Ordinance
• *Enhanced due diligence: Beyond SECO reporting, conduct additional investigations under Article 6 of the Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious activity reporting: If enhanced due diligence cannot resolve suspicions, file reports with the Financial Intelligence Unit (FIU) under Article 9 GwG without delay
• *Sanctions screening updates: Refresh sanctions list screening tools and counterparty databases to reflect the new price cap threshold and any related entity additions

What changed

• The primary regulatory change is a downward adjustment of the Russian crude oil price cap:
• Previous cap: USD 47.6 per barrel
• New cap: USD 44.1 per barrel
• Effective date: February 1, 2026 This modification targets Russia's shadow fleet and circumvention mechanisms. As context, Switzerland previously expanded its sanctions framework on December 12, 2025, subjecting 116 vessels—primarily tankers in Russ

Who is affected

• *Primary obligations fall on:
• Financial intermediaries
• Entities engaged in Russian crude oil trade
• Firms with exposure to sanctioned Russian entities
• *Secondary impact on:
• International trading companies with Swiss counterparties
• Logistics and shipping providers facilitating energy transactions
• Compliance and legal departments managing sanctions screening

Related regulations

• *Recent regulatory escalation
• *EU enforcement phase
• *Enhanced AML requirements
• *FINMA supervisory approach