Swiss Sanctions Against Belarus — Federal Council Ordinance (2020–present)

Belarus Virtual Consult

Switzerland, despite not being a member of the European Union, maintains its own autonomous sanctions regime against Belarus adopted by the Federal Council under the Embargo Act (EmbG). Swiss Belarus sanctions broadly mirror EU measures, reflecting Switzerland's longstanding policy of aligning with EU restrictive measures in cases involving serious human rights violations, while adapting them where necessary to the Swiss legal framework.

Legal Basis

The Swiss sanctions against Belarus are implemented through the Ordinance on Measures against Belarus (SR 946.231.116.9), adopted by the Federal Council under the Federal Act on the Implementation of International Sanctions (Embargo Act). The State Secretariat for Economic Affairs (SECO) is responsible for administering the financial and economic aspects of the regime, while the Federal Department of Foreign Affairs (FDFA) oversees the diplomatic dimension.

October 2020 — Initial Alignment

Switzerland adopted its first Belarus sanctions in October 2020 in alignment with the EU's initial packages, focusing on travel bans and asset freezes for officials responsible for the fraudulent August 2020 election and the subsequent repression.

August 2021 — Comprehensive Economic Measures

On 11 August 2021, Switzerland substantially revised and expanded its Ordinance on Measures against Belarus, entering into force at 6pm CEST. The expanded measures included:

Export restrictions: ban on internet and telephone interception equipment; prohibition on dual-use goods exports for military purposes; embargo on tobacco production and processing equipment
Import restrictions: ban on petroleum products of Belarusian origin; import ban on potassium chloride (potash) from Belarus
Financial restrictions: prohibition on issuance, trading and placement of financial instruments by the Belarusian government and three major state banks; ban on providing loans to designated entities; insurance and reinsurance service restrictions; financial sanctions on Belaeronavigatsia (state air navigation provider)

Aviation Measures

Following the forced diversion of the Ryanair flight in May 2021, Switzerland imposed an aviation ban mirroring the EU measure, prohibiting Belarusian carriers from Swiss airspace and airports.

Subsequent Updates

Switzerland has updated its Belarus sanctions ordinance on multiple occasions, maintaining close alignment with EU measures while going through its own domestic legislative process. Updates have covered:

New individual and entity designations
Extension of sectoral trade restrictions
Additional financial sector measures
Expanded export controls on dual-use goods and technology

Scope

Swiss Belarus sanctions apply to all persons and entities in Switzerland, as well as to Swiss nationals and Swiss-domiciled companies operating abroad. SECO publishes the consolidated list of all designated individuals and entities and provides compliance guidance for Swiss financial institutions and businesses.

Position within Swiss Foreign Policy

Switzerland's decision to align with EU Belarus sanctions — as with its decision to align with EU Russia sanctions following the February 2022 invasion of Ukraine — represented a significant departure from Switzerland's traditional policy of strict neutrality in interstate conflicts. The Federal Council justified the measures on the grounds of the grave human rights violations involved, which it considered to fall outside the scope of neutrality considerations.