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.

More details, visit https://www.seco.admin.ch.

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:

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.