149 days later: why Bern does not adopt EU sanctions by default
The EU adopted its Belarus package in April; Bern implemented the last measures only 149 days later. That is not an oversight but a consequence of Switzerland's independent sanctions policy – with benefits and risks.
Switzerland has tightened its sanctions against Belarus. Expanded trade bans now apply, along with restrictions on certain crypto transactions and prohibitions on individual security and tourism services. Politically notable, however, is not only what has been banned since 19 September but when: the European Union had already adopted the package on 23 April. Between the two dates lie 149 days.
That difference is neither an editorial error nor necessarily a sign of delayed implementation. It follows the Swiss model: EU sanctions do not automatically become Swiss law. The Federal Council decides case by case whether to adopt them in full, in part or not at all. This is precisely where the tension lies between national autonomy and the most seamless possible coordination of economic pressure.
Two decisions instead of automatic adoption
Switzerland implemented the EU's 20th sanctions package in stages. On 22 May, the Department of Economic Affairs, Education and Research added two Belarusian companies to the Swiss sanctions lists. The Federal Council only decided on the remaining measures on 18 September; they entered into force one day later.
The reason for the delay is in principle rooted in the Embargo Act. According to SECO, Switzerland is not obliged to adopt EU sanctions. The Federal Council weighs foreign policy, foreign economic policy and legal criteria. That review allows for deviations and exemptions but takes time. SECO itself notes that the adoption of EU measures is therefore announced later than in Brussels.
The legal dividing line matters: an EU ban does not apply in Switzerland simply because it was decided in Brussels. What counts is the Swiss ordinance and its annexes. Companies with activities or subsidiaries in the EU area may, however, be subject to other jurisdictions at the same time. The Swiss decision therefore does not create new obligations everywhere, but it ends a phase in which the rulebooks diverged.
What is added after 149 days
The new package expands export bans on goods that could strengthen Belarus militarily, technologically or industrially. The list of goods and technologies whose transit through Belarus is prohibited is also extended. Further import restrictions cover products that generate substantial export earnings for the country.
Financial and services rules come on top. Certain transactions with crypto assets and central bank digital currencies are banned, explicitly including those involving the digital Belarusian ruble. Transactions with crypto service providers based in Belarus and with decentralised platforms are also covered. Newly prohibited are managed security services for the Belarusian state and its public bodies, as well as services related to tourism activities in the country.
The EU justifies the tightening with the Lukashenko regime's support for Russia's war against Ukraine. Its April package aimed to align the Belarus rules further with the Russia sanctions. Switzerland now adopts the same principle, but on its own legal basis.
A gap – but no evidence of circumvention
The 149 days mean that the new sectoral EU bans were not mirrored in Swiss law during that period. That does not, however, mean that Swiss actors actually used the gap for circumvention. The published documents provide no evidence of this. Moreover, existing Swiss sanctions, export controls or the rules of other states may already have applied.
The case nevertheless reveals a structural risk: the longer jurisdictions diverge, the more complex goods classification, payment channels and corporate compliance become. SECO advises companies to check not only the customs tariff number and technical characteristics but also the end user, the intended use and indirect supply chains. Companies themselves are responsible for compliance.
Independence needs visible justifications
The effect of sanctions cannot simply be read off a single number either. SECO describes it as hard to measure and stresses that broadly supported, gap-free implementation is more effective than isolated action. At the same time, the Swiss procedure allows for its own legal and economic policy assessment – precisely because Switzerland is not a member of the EU.
The decisive question therefore remains political: how much delay is the price of a careful, independent review, and from what point does it weaken the coordination that is actually wanted? The new Belarus package closes the specific gap. But it does not remove the fundamental dilemma. The longer Bern takes for future decisions, the more important a transparent explanation becomes of which review justifies that time.
Sources
- SECO: Switzerland adopts further EU sanctions against Belarus, 18 September 2026
- SECO: FAQ on legal bases, responsibilities and delays in sanctions
- SECO: Measures concerning Belarus and the annexes in force
- EAER/SECO: Expansion of the Swiss sanctions lists, 22 May 2026
- Council of the EU: 20th sanctions package against Russia and Belarus, 23 April 2026
- Fedlex: AS 2026 480 – Amendment of the Ordinance on Measures against Belarus
