Sanktionen: Russland und Belarus

Key dates

2026-11-03

The EAER expanded and amended the Swiss sanctions lists relating to Russia and Belarus.

2026-11-04

The Federal Council decided to adopt the EU’s 21st Russia and Belarus sanctions package and related measures.

2026-11-04

The amended sanctions lists entered into force at 23:00 Swiss time.

2026-11-05

The sectoral measures, including the strengthened crypto-sector restrictions and transaction prohibitions, entered into force.

Suggested considerations

• Compliance teams may wish to refresh sanctions screening against the amended Swiss Russia and Belarus lists, including customer, beneficial-owner, authorised-signatory, counterparty and payment screening records.
• Swiss crypto-sector companies should consider reviewing ownership registers, pending acquisitions, shareholder changes, control arrangements and beneficial-ownership information for Russian nationals and persons resident in Russia, including indirect acquisition structures.
• Firms should consider mapping exposure to the newly prohibited banks, financial institutions, crypto-service providers and other entities, and placing appropriate holds on affected transactions and assets pending resolution.
• Financial intermediaries may wish to document asset-freeze decisions and report affected business relationships to SECO in accordance with the applicable Ukraine sanctions ordinance.
• Where sanctions-related facts create suspicion of money laundering or terrorist financing, firms should consider completing the additional clarifications required by Article 6 AMLA and filing an immediate report under Article 9 AMLA if the suspicion cannot be dispelled.
• Firms may wish to update sanctions procedures, transaction-monitoring scenarios, onboarding questionnaires and escalation controls to distinguish SECO sanctions reporting from separate AMLA reporting.
• Compliance teams may wish to review external exposure to EU sanctions controls as well as Swiss measures; independent Swiss sanctions commentary describes the regime as not being a general Russia or Belarus embargo, but highlights continuing expansion of financial, crypto, services and circumvention controls.

What changed

The EAER expanded and amended the Russia and Belarus sanctions lists, adding 254 individuals, companies and organisations to measures including asset freezes and restrictions on making funds or economic resources available. Switzerland also introduced transaction prohibitions covering, among others, 33 Russian banks, one bank in a third country, 17 financial institutions and crypto-service providers, five third-country companies, four Russian airports and two Russian ports. The specific crypto-sector ownership restriction prohibits Russian nationals and persons resident in Russia from acquiring ownership in Swiss companies that provide services in the crypto sector, without limiting the rule to a particular crypto service. Financial intermediaries must implement the applicable prohibitions

Who is affected

• Swiss banks and securities firms maintaining relationships with Russia- or Belarus-linked customers
• Swiss crypto-asset service providers and other Swiss companies providing crypto-sector services
• Swiss financial intermediaries subject to the Ukraine sanctions ordinance and AMLA
• Crypto exchanges, custodians and other financial institutions dealing with listed counterparties or assets
• Corporate service providers, investors and beneficial owners involved in acquisitions of Swiss crypto-sector companies

Related regulations

• Swiss Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance)
• Swiss Anti-Money Laundering Act (AMLA; GwG), Article 6
• Swiss Anti-Money Laundering Act (AMLA; GwG), Article 9
• FINMA supervisory and enforcement framework