Being not an EU member and therefore not required to support the full package of restrictive measures imposed on Russia, Switzerland omitted the direct unilateral application of the European sanctions but opted notwithstanding in favour of the implementation of an alleviated version ensuring that the Swiss financial centre must not be used to circumvent said financial sanctions.
The measures envisaged to prevent the circumvention as laid down in the Swiss Ordinance include:
- In the field of finance, trade in new financial instruments with a maturity exceeding 30 days issued by five Russian banks and six companies, and the granting of loans with a maturity exceeding 30 days to those five banks and six companies, are subject to authorization. Secondary trading in newly issued financial instruments from outside Switzerland and the EU with a maturity exceeding 30 days is subject to a duty to notify. Twenty-four names have been added to the existing list of persons and companies with whom financial intermediaries are prohibited from entering into new business relationships with, and whose existing business dealings are subject to a duty to notify.
- With regard to specific military goods and dual-use goods subject to licence, the provision of services or technical assistance to nine newly listed mixed companies in Russia are subject to a duty to notify. Services in connection with aerospace are exempt. Certain services necessary for deep water oil exploration and production, arctic oil exploration and production and shale oil projects in Russia are subject to a duty to notify