Sanctions in the RU-UA conflict – Update 4.0


Situation in Switzerland

On 3 May 2022, the Department of Economics, Education and Research (Departement für Wirtschaft, Bildung und Forschung = WBF) adjusted the list of persons in Annex 8 of the ordinance on measures related to the ongoing conflict between Russia and the Ukraine. As a result, two natural persons were added to Annex 8. The measures came into force on 4 May 2022 at 6p.m.

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Action required and outlook

When should you start thinking about export controls and sanctions?

  • Basically, whenever you buy, export, lend or conduct any kind of provision of items (economic resources), including the provision of technology, know-how or services outside your country of domicile.

What are the goals of export control and sanctions management?

  • Business continuity through a flexible and resilient supply chain and efficient, compliant transactions.
  • Protection of the company's reputation and its position as a trustworthy business partner against bad image and irreparable damage.
  • Automation and optimisation of processes.
  • Enabling of traceability and reporting.
  • Improving governance.
  • Avoidance of sanctions (blacklisting, import/export restrictions and withdrawal of permits).
  • Avoidance of fines as well as contractual penalties and imprisonment (personal liability).

Basically, all types of economic operators are affected, especially in international trade. Whether a permit is required depends in particular on the following four questions:

Where do you deliver to?

Is the delivery or final destination country subject to an embargo?

Who is involved in the transaction?

Are any of your business partners (including banks) on any of the sanctions lists?

Why are you delivering your items?

What is the end use? Are the goods connected in any way with ABC weapons?

What items are you supplying?

Are the goods on any goods control lists?

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

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 May 09, 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, Basel , PwC Switzerland

+41 58 792 53 51


Katharina Scheiber

Senior Consultant Tax & Legal Services, PwC Switzerland

+41 58 792 5100