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The Swiss State Secretariat for Economic Affairs suspended export licences and licence exemptions for controlled dual-use goods to Ukraine, thereby making such goods subject to individual review. On Wednesday 13 August, in light of the recent EU sectoral sanctions, the Swiss Federal Council announced further measures aimed at avoiding circumvention of sanctions relating to the situation in Ukraine.

 With immediate effect, Switzerland has extended the suspension of war material exports to Russia and Ukraine to ‘special military goods’ as defined in the Swiss Goods Control Act. Goods such as drones, training equipment, simulators and radio devices will be banned, whilst export licences for dual-use goods are to be examined on a case-by-case basis. Export control authorities have been instructed to deal restrictively with dual-use goods export licences.

 For the full announcement (in German), please click here. It should be noted that, in line with existing policy, the Swiss cabinet stopped short of imposing sanctions on Wednesday. Therefore, the Swiss response to the crisis in Ukraine currently remains limited to restrictive measures designed to avoid the use of its territory for the circumvention of sanctions imposed by the international community, and is not a sanctions regime in itself


Philippe Reich is the head of Baker & McKenzie's Antitrust and Trade Law Practice Group in Switzerland and a member of the European Competition Law and transactional practice groups. He is a member of the EMEA Steering Committee of the International Trade and Commerce Practice Group and of the Global Steering Committee for the Firm's India Practice. He is also the Chairman of the Swiss Indian Chamber of Commerce and forms the Indian Desk in Switzerland. Mr. Reich regularly publishes articles on Swiss antitrust and trade laws and the Swiss-EU as well as Swiss-Indian bilateral relations.

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