Aktualisierte Sanktionsmeldung: Russland

What Changed

• The primary regulatory change is a downward adjustment of the Russian crude oil price cap:
• Previous cap: USD 47.6 per barrel
• New cap: USD 44.1 per barrel
• Effective date: February 1, 2026 This modification targets Russia's shadow fleet and circumvention mechanisms. As context, Switzerland previously expanded its sanctions framework on December 12, 2025, subjecting 116 vessels—primarily tankers in Russ

Suggested Considerations

• *Implement price cap enforcement: Update transaction monitoring systems to flag and block crude oil transactions exceeding USD 44.1 per barrel from Russian sources
• *Asset freezing: Continue blocking assets of sanctioned persons and entities; verify no new transactions circumvent the lower threshold
• *Reporting obligations: Report affected business relationships to SECO in accordance with the Sanctions Ordinance
• *Enhanced due diligence: Beyond SECO reporting, conduct additional investigations under Article 6 of the Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious activity reporting: If enhanced due diligence cannot resolve suspicions, file reports with the Financial Intelligence Unit (FIU) under Article 9 GwG without delay
• *Sanctions screening updates: Refresh sanctions list screening tools and counterparty databases to reflect the new price cap threshold and any related entity additions

Key Dates

Who is Affected