Sanctions in the RU-UA conflict – Update 2.0


RU-UA conflict: Implementation of further EU sanctions

In response to Russia’s ongoing invasion of Ukraine, the Federal Council took the decision on 25 March 2022 to adopt further sanctions against Russia, thereby implementing the Federal Council decision of 18 March 2022 to adopt the latest package of EU sanctions. The measures came into force at 11pm on 25 March 2022.

For further information please follow the link specifying the EU sanctions in more detail.

Situation in Switzerland

The Federal Council decision of 25 March 2022 means that Switzerland remains in line with the measures imposed by the EU on 9 and 15 March 2022 in response to Russia’s ongoing invasion of Ukraine.

Newly prohibited:

  • The export of goods and related services for the Russian energy sector;
  • The participation in businesses active in the energy sector and the provision of loans or other financial resources to such businesses;
  • The import of iron and steel goods from Russia, or originating in Russia;
  • The export of luxury goods and maritime navigation goods to Russia;
  • Transactions with certain state-owned companies; as well as
  • The provision of credit rating services.

Further, the Federal Council has decided to allow certain exceptions from the financial sanctions for humanitarian purposes. This eases business relationships necessary for the work of humanitarian organisations.

This means that all measures contained in the EU’s fourth package of sanctions have been implemented.

However, the Federal Council took the decision not to implement the EU measure of 1 March 2022 suspending the broadcasting of contents from certain Russian media outlets, namely Sputnik and Russia Today. The Federal Council is of the opinion that it is more effective to counter untrue and harmful statements with facts instead of preventing them from being broadcast.

Details under

We are monitoring the current situation still with great concern, as there is a risk of significant further escalations. Sanctions in the form of import restrictions as well as export control restrictions can have an impact on your company.

Action required and outlook

With this tranche, the already existing sanctions were extended again.

Economic operators should continuously check what effects the existing sanctions have on their business relationships, as misconduct will be punished with severe sanctions.

Against the background of the constant expansion of sanctions, companies should check what influence the existing and planned restrictions will have, especially since the enacted regulations will come into force immediately. If necessary, the business processes must be adjusted immediately.

In this context, we support you with the strategic definition of the derived requirements and the operational implementation.


This newsletter reflects the status as of March 28, 2022. We would like to point out that the political situation is extremely dynamic and there may be short-term changes in the law.

As part of this newsletter, we will keep you informed of all further developments.

Your contact persons

Simeon L. Probst

Partner, Customs & International Trade, PwC Switzerland

+41 58 792 53 51


Katharina Scheiber

Senior Consultant, Trade Compliance & Export Controls Expert, PwC Switzerland

+41 58 792 56 95