The Federal Council adopted the 19th EU sanctions package against Russia and Belarus by decision of 25 February 2026; the amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72) entered into force on 26 February 2026. That is roughly four months after the Brussels Council decision of 23 October 2025. With this step, the operational dividing line between Swiss and EU sanctions practice — which had survived in numerous SPAs as a separate sanctions carve-out — has collapsed. What remains is enforcement granularity.

The package has four concrete strands. In the energy sector, a phased LNG ban: new contracts from 25 April 2026, pre-existing long-term supply contracts until end-2026. In the financial sector, the blocking of additional Russian banks and financial institutions in Belarus and Kazakhstan. In the crypto sector, a new prohibition on services for the benefit of Russian recipients, specifically targeting the A7A5 stablecoin. For the shadow fleet, additional vessel designations. Switzerland’s designation list covers approximately 2,600 natural persons, companies and organisations — identical to the EU list for Russia and Belarus. Persons designated solely under thematic EU sanctions regimes appear on the EU list, not the Swiss one. Anyone who previously argued that a counterparty appeared “only” on the EU list has lost that argument.

Until 2022, Swiss practice diverged from the EU’s in predictable ways: narrower designations, longer lead times for adoption, a softer reading of trust and foundation structures. Swiss law firms built entire memo series on that assumption. Art. 2 of the Embargo Act (EmbG, SR 946.231) gives the Federal Council broad authority to adopt sanctions, but political instinct held it back. Since February 2022, and now confirmed by the 19th package, the presumption has reversed: adoption is the rule; departures require individual justification by the Federal Council.

What remains is the enforcement layer. SECO receives reports, conducts reviews and demands asset freezes; violations under Art. 9 EmbG are prosecuted by SECO itself as the competent federal authority under administrative criminal law — with the power to issue penalty orders and to refer particularly significant cases to the Office of the Attorney General. The difference from OFAC practice is not a lack of centralisation but rather the instrument: administrative criminal law under the VStrR, not civil administrative sanctions. The reporting obligation to SECO mirrors the EU obligation; the administrative pressure behind it does not. No adviser can any longer invoke the absence of a Swiss adoption — the remaining room for manoeuvre lies in enforcement intensity.

For M&A practice, the consequence is precise: sanctions representations in a Swiss SPA no longer need a separate “Swiss law applicable sanctions” standard; the list is the EU list. Indemnity caps for sanctions breaches should, however, continue to distinguish between a violation occurring in Switzerland and one occurring through an EU affiliate. The standard is the same everywhere; the expected loss diverges.

What remains open is how SECO will apply the new crypto provisions against Swiss VASPs, in particular where stablecoin bridges route through third countries. An updated interpretive guidance note from SECO, or a first criminal judgment on a violation under the 19th package, will settle the question. Until then, anyone invoking Swiss sanctions autonomy is arguing about enforcement granularity.