Sanctions database

Prohibitions do not apply to the sale, delivery, export, transit and transport of goods and technologies or to the provision of related services, if the goods and technologies are intended for:
a. exclusively humanitarian and medical activities carried out by an impartial humanitarian organization, health emergencies, the urgent avoidance or containment of an event that is likely to have serious and significant effects on the health and safety of people or the environment, or the coping with natural disasters;
b. medical or pharmaceutical purposes;
c. the temporary export of items for use by news media;
d. software updates;
e. the use as communication devices of daily use;
f. ensuring cyber security and information security for natural and legal persons, organizations and institutions in Belarus with the exception of its government and the companies directly or indirectly controlled by it; or
g. the personal use of the following items by natural persons traveling to Belarus 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 SECO can grant exemptions from the prohibitions for activities intended for the following civilian purposes or civilian end recipients:
a. the cooperation between Switzerland and Belarus in exclusively civil matters;
b. the intergovernmental cooperation in space programs;
c. the operation, maintenance and reprocessing of fuel elements, the security of civil nuclear capacities as well as civil nuclear cooperation, especially in the field of research and development;
d. maritime security;
e. civil telecommunications networks, including the provision of Internet services;
f. the use by organizations that are owned or under the sole or joint control of a legal person, organization or institution founded or registered under Swiss law or the law of a partner; or
g. diplomatic representations of Switzerland or its partners.

After consultation with the responsible departments of the FDFA and the FDF, SECO may authorize participation in an investment in projects that are co-financed from the Russian Direct Investment Fund or a contribution to such projects after it has determined that this participation in the investment or this contribution is required for the performance of contracts entered into before March 5, 2022 or as a result of ancillary agreements.

The prohibition specified in paragraph 1 does not apply to the sale, delivery, transfer or export of banknotes denominated in Swiss francs or euros if this sale, delivery, transfer or export is necessary:
a, for personal use by natural persons traveling to the Russian Federation or their close relatives traveling with them; or
b, for the fulfillment of official purposes of diplomatic or consular missions or an international organization in the Russian Federation,

After consultation with the responsible offices of the Federal Department of Foreign Affairs (FDFA), SECO may grant exceptions to the prohibitions if this is necessary to urgently avert or contain an event that is likely to have serious and significant effects on human health and safety or on the environment.
In addition, in urgent and duly justified cases, goods listed in Annex 4 may may be sold, delivered, exported or transited without prior authorization without prior authorisation, provided the exporter notifies SECO of the sale, delivery, export or transit within five working days and the relevant reasons.

SECO may approve exceptions to the prohibitions in paragraphs 1, 4 and 5 for the performance of finance lease agreements for aircraft concluded before 5 March 2022 if:
a. this is necessary for the payment of leasing installments to legal persons, companies or organizations incorporated or incorporated under Swiss law or the law of a member state of the European Economic Area (EEA) which are not subject to measures under this Ordinance; and
b. no further economic resources are made available to the Russian contractual partner apart from the transfer of ownership of the aircraft after the full settlement of the leasing liabilities. (added 27.04.2022)

Limited exemptions apply, including when the mentioned goods and certain related services are necessary for the delivery of fossil fuels, such as coal, oil and natural gas, from or through Russia to Switzerland or EEA countries. From 27 April – the transport of natural gas and petroleum, including refined petroleum products, from or through Russia to Switzerland or the EEA, the urgent prevention or containment of an event that is expected to have serious and significant effects on the health and safety of people and the environment.
In limited circumstances, SECO may also, upon consultation with other relevant federal departments, authorise derogations from this prohibition if: a. this is necessary to ensure the energy supply of Switzerland or an EEA member state in the event of an imminent or already existing serious shortage; or b. the goods or services are intended for the exclusive use of organizations owned or controlled in whole or in part by an organization incorporated or incorporated under Swiss law or the laws of an EEA Member State.
In duly justified cases of urgency, the sale, delivery, transfer or export may take place without prior authorization provided that the exporter notifies SECO of this within five working days of the sale, delivery, transfer or export and the relevant reasons for sale, supply, transfer or export without prior approval.

This prohibition does not apply to Swiss nationals, nationals of an EEA member state and natural persons who have a temporary or permanent residence permit from Switzerland or an EEA member state,

After consultation with the FDFA and the FDF, SECO may authorize exceptions to the prohibition in paragraph 1 if this is absolutely necessary to ensure Switzerland’s financial stability,

Diplomatic, medical and humanitarian flights are exempt from the measure.