On 30 October 2025, Switzerland adopted the EU’s 18th package of sanctions against Russia and Belarus in full.
Source: RBC
This step represents more than an act of political alignment — it reshapes the operational environment for European businesses with exposure to Russia or cross-border ties with Turkey.
From finance to energy and trade, companies must now reassess how sanctions affect contractual obligations, supply chains, and reputational standing.
What Has Changed
1.Banking and Financial Transactions
- 45 Russian banks are now completely excluded from the Swiss financial system.
- Any transactions routed through these institutions or their intermediaries are subject to immediate blocking.
2.Export Controls
- Expanded bans now cover chemical components for fuel, certain metals, and plastics.
- Stricter monitoring applies to all goods potentially originating from or transiting through Russia.
3.Energy Restrictions
- Import of oil products derived from Russian crude — even via third countries — is prohibited (with narrow exceptions).
- Switzerland also suspended participation in Nord Stream 1 and 2 pipeline projects, affecting technical and financial cooperation.
4.Targeted Sanctions
- 14 individuals and 41 entities have been added to the Swiss asset-freeze list.
- Restrictions now apply to over 100 ships linked to third-country operators carrying Russian goods.
Legal and Compliance Implications for European Companies
1.Financial and Banking Exposure
European businesses using Swiss or EU-based banks must verify whether their institutions or intermediaries appear on sanctions lists.
Cross-border transactions involving Turkey or Russia should undergo enhanced due diligence to prevent inadvertent breaches.
2.Supply-Chain and Export Risks
Companies trading in industrial goods, metals, plastics, or fuel additives must review origin documentation and end-use declarations.
Even indirect dealings through Turkey or neutral countries could trigger secondary-sanction risks.
3.Contractual Obligations
Existing agreements with Russian or Turkey-based partners should include explicit sanctions clauses, granting parties the right to suspend or terminate obligations if sanctions make performance illegal.
4.Energy and Infrastructure Projects
Long-term investment and service contracts in the energy sector may be affected by restrictions on technical cooperation. It is advisable to review project structures, financing models, and arbitration clauses in anticipation of potential enforcement challenges.
5.Reputation and Regulatory Compliance
Banks, auditors, and regulators now expect proactive sanctions compliance. Non-compliance can result in frozen accounts, cancelled transactions, or reputational damage.
European businesses using Swiss or EU-based banks must verify whether their institutions or intermediaries appear on sanctions lists.
Cross-border transactions involving Turkey or Russia should undergo enhanced due diligence to prevent inadvertent breaches.
2.Supply-Chain and Export Risks
Companies trading in industrial goods, metals, plastics, or fuel additives must review origin documentation and end-use declarations.
Even indirect dealings through Turkey or neutral countries could trigger secondary-sanction risks.
3.Contractual Obligations
Existing agreements with Russian or Turkey-based partners should include explicit sanctions clauses, granting parties the right to suspend or terminate obligations if sanctions make performance illegal.
4.Energy and Infrastructure Projects
Long-term investment and service contracts in the energy sector may be affected by restrictions on technical cooperation. It is advisable to review project structures, financing models, and arbitration clauses in anticipation of potential enforcement challenges.
5.Reputation and Regulatory Compliance
Banks, auditors, and regulators now expect proactive sanctions compliance. Non-compliance can result in frozen accounts, cancelled transactions, or reputational damage.
Recommendations from the Russian-Turkish Law & Consulting Firm
- Audit your counterparties and banking partners.
- Update all contracts.
- Reassess supply chains.
- Diversify financial channels.
- Train internal compliance teams.
Strategic Insight
These new measures signal a decisive shift — even historically neutral jurisdictions like Switzerland now enforce full alignment with EU sanctions.
For European firms engaging with Russia or Turkey, compliance is no longer a formality — it is a strategic pillar of risk management.
Those who adapt early will not only protect their operations but gain trust and leverage in a tightening regulatory landscape.
How We Help
At Russian-Turkish Law & Consulting Firm, we provide:
- Comprehensive sanctions and compliance audits
- Contract drafting and revision aligned with EU and Swiss requirements
- Due-diligence checks on banks and counterparties
- Representation in international arbitration and cross-border litigation
Our firm bridges legal expertise across Russia, Turkey, and Europe — ensuring your business stays compliant, agile, and secure.
