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Swiss Sanctions Regime: Key Facts and Insights

To ensure compliance with international sanctions, Switzerland has implemented its own set of regulations to curb activities that contravene economic sanctions laws. Here are some key takeaways from the Swiss sanctions regime.

Territorial Application

The principle of territoriality applies in Switzerland, meaning that sanctions are applicable only to facts occurring within and actions taken in Switzerland.

Blocking and Freezing Assets

Most Swiss sanctions regimes require assets owned or controlled by sanctioned entities to be blocked or frozen.

Licenses and Authorizations

  • The Federal Council may grant exceptions for humanitarian activities or to safeguard Swiss interests.
  • Licenses can also be issued by the State Secretariat for Economic Affairs (SECO) or other agencies.

Reporting Requirements

Individuals or institutions holding assets owned or controlled by sanctioned entities must report to the SECO, providing information on: + Beneficiaries + Asset specifications

Compliance Expectations

Switzerland expects companies to implement robust compliance programs to prevent violations of economic sanctions laws.

Penalties and Enforcement

  • Criminal penalties can be imposed for violating economic sanctions laws.
  • Civil penalties are not currently applicable in Switzerland.
  • The SECO and other authorities are responsible for investigating and enforcing sanctions violations.

Appeals Process

There is no civil enforcement process or appeal mechanism, as civil penalties do not exist under Swiss law.

International Cooperation

Switzerland engages in international cooperation with other countries to implement and enforce economic sanctions laws.

Future Developments

  • Discussions are ongoing regarding the implementation of thematic sanctions regimes, similar to those adopted by the EU.
  • Efforts are being made to coordinate with international partners on potential expropriation of Russian funds to finance Ukraine reconstruction.

For more information on Switzerland’s sanctions regime, please visit the State Secretariat for Economic Affairs’ website at [Hyperlink].