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Sanctions in the RU-UA conflict – Update 5.0


Ukraine: adoption of further EU sanctions against Russia and Belarus

In view of the seriousness of the situation and in response to the ongoing conflict in Ukraine, the EU adopted new sanctions against Russia (sixth package of sanctions) on 3 June 2022.

The EU’s sixth package of sanctions includes an embargo on crude oil and certain refined petroleum products from Russia. This embargo will be brought into force progressively in the EU, taking full effect by the beginning of 2023 following several transitional periods. In the financial sector, the provision of audit and business consulting services is now prohibited. The bans on the provision of services to trusts have been made more precise. In addition, the EU is prohibiting businesses from advertising in content produced or broadcast by certain Russian media such as Russia Today or Sputnik.

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


Situation in Switzerland

On 10 June 2022, the Federal Council decided to adopt these measures and instructed the Department of Economic Affairs, Education and Research (Wirtschaft, Bildung und Forschung, ‘WBF’) to adapt the ordinance on measures in connection with the situation in Ukraine. In addition, the WBF, together with the Federal Department of Finance (Eidgenössische Finanzdepartement, ‘EFD’) and the Federal Department of the Environment, Transport, Energy and Communications (Eidgenössisches Departement für Umwelt, Verkehr, Energie und Kommunikation, ‘UVEK’), will examine in detail the consequences for Switzerland of imposing the oil embargo.

The WBF has also approved the sanctioning of over 100 further Russian and Belarusian individuals and entities. These are members of the army, figures active in politics and in the field of communication/propaganda, as well as people from oligarch circles and their family members, including Aleksandra Melnichenko.

The Swiss list of sanctioned persons and organisations corresponds fully to that of the EU.

It also approved the exclusion of four new Russian and Belarusian banks, including Sberbank, Russia’s largest bank, from the SWIFT messaging system.

The list of export-banned goods that could contribute to Russia’s military and technological strengthening or the development of its defence and security sector, as well as the list of economically important goods prohibited for import, have also been expanded.

These amendments came into force at 6pm on 29 June 2022.

More details, visit

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 penalties.

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, business processes must be adjusted immediately.

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


This newsletter reflects the status as of July 25, 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