Sanctions database

Actions that are necessary for the official work of diplomatic or consular missions or international organizations, for humanitarian activities, and for hospitals or educational institutions based in the areas specified in Annex 6 are exempt from the prohibitions.
The Government or, within the scope of its competence, SECO may grant exceptions to the prohibitions if this is necessary to prevent or contain an event that is likely to have serious and significant effects on the health and safety of people, including the security of existing infrastructure, or the environment will have.
In duly justified cases of urgency, the sale, supply, transfer or export may take place without prior authorization provided that the exporter informs the Government or, within its competence, SECO within five working days of the sale, supply, transfer or of export and gives a detailed explanation of the relevant reasons for the sale, delivery, transfer or export without prior authorisation.

The prohibition does not apply to: a) binding commitments related to the provision of funding or grants entered into before 4 March 2022; b) the provision of public funds or financial assistance up to a total value of 10 mln euros or the equivalent in Swiss francs per project in favor of small and medium-sized enterprises established in an EEA signatory state or in Switzerland; c) the provision of public funding or financial assistance for food trade, agricultural, medical or humanitarian purposes.

does not apply to transactions that were contractually agreed before February 25, 2022.

except for the granting of loans for the following purposes:
a) to finance trade between the EEA signatory states or between Switzerland and third countries that is not affected by this Ordinance;
b) to finance the costs required for the fulfillment of a commercial contract according to lit. a necessary deliveries of goods and services from the EEA contracting states or third countries.
The prohibition does not apply to withdrawals and payments based on a contract concluded before February 25, 2022 if the following requirements are met:
a) All terms of such eligibility or disbursement have been: 1. Agreed before February 25, 2022; and 2. no longer modified on or after this date.
b) It was contracted before February 25, 2022, on which date full repayment of all funds provided is due and all obligations, rights and obligations arising from the contract expire.

The prohibition pursuant to paragraph 1 does not apply if the relevant services are required to urgently prevent or contain an event that is likely to have serious and significant effects on human health and safety or the environment. The service provider shall notify the Government, or SECO where it is responsible, within five working days of any activity under this paragraph and shall set out the relevant reasons for providing the service.

The prohibitions and licensing requirements under Articles 5 and 6 do not apply to goods and services intended for: a) exclusively humanitarian and medical activities carried out by an impartial humanitarian organisation, public health emergencies, the urgent prevention or containment of an event likely to have serious and significant effects on human health and safety or the environment, or coping from natural disasters; b) medical or pharmaceutical purposes; c) the temporary export of items for use by news media; d) software updates; e) use as everyday communication devices; f) ensuring cybersecurity and information security for natural and legal persons, entities and bodies in the Russian Federation with the exception of their government and the companies directly or indirectly controlled by it; or g) the personal use of the following items by natural persons traveling to the Russian Federation or family members traveling with them, provided that the items are owned by the persons concerned and are not intended for sale: 1. personal items; 2. household items; 3. vehicles or work equipment.
The Government or, within the scope of its competence, SECO may grant exceptions to the prohibitions in accordance with Art. 5 para. 1 and 2 let. a and Art. 6 para. 1 and 2 let. a permit for activities intended for the following civilian purposes or civilian end recipients: a) cooperation between Liechtenstein or Switzerland and the Russia in exclusively civil matters; b) Intergovernmental cooperation in space programs; c) the operation, maintenance and reprocessing of fuel elements, the safety of civil nuclear capacities and civil nuclear cooperation, particularly in the field of research and development; d) maritime security; e) civil telecommunications networks, including the provision of internet services; f) use by any entity owned, solely or jointly controlled by any legal person, entity or body incorporated or incorporated under the laws of Liechtenstein or Switzerland or the laws of a partner; or g) diplomatic representations of Liechtenstein or Switzerland or their partners.
The Government or, within the scope of its competence, SECO shall refuse to grant exceptions pursuant to paragraph 2 if there is reason to believe that the goods or services are intended for: a) a military final recipient or a natural person, company or organization as specified in Annex 2; b) the aerospace industry; c) an activity for the energy sector, unless this activity is permitted under Art. 12 (3) to (5). (added 02.05.2022)

The Government or, within the scope of its competence, SECO may grant exemptions from the prohibitions set out in paragraphs 1, 4 and 5 for the performance of finance lease agreements for aircraft concluded before March 5, 2022 if:
a) this is required for the payment of leasing installments to legal persons, companies or organizations incorporated or incorporated under the laws of an EEA Contracting State or Switzerland which are not subject to measures under this Ordinance; and
b) no further economic resources other than the transfer of ownership of the aircraft are made available to the Russian contractual partner after the full settlement of the leasing liabilities. (added 04.05.2022)

The Government or, within the scope of its competence, SECO may grant exemptions from the prohibitions set out in paragraphs 1, 4 and 5 for the performance of finance lease agreements for aircraft concluded before March 5, 2022 if:
a) this is required for the payment of leasing installments to legal persons, companies or organizations incorporated or incorporated under the laws of an EEA Contracting State or Switzerland which are not subject to measures under this Ordinance; and
b) no further economic resources other than the transfer of ownership of the aircraft are made available to the Russian contractual partner after the full settlement of the leasing liabilities. (added 04.05.2022)