Russian oil deals: a US waiver would not be a Swiss free pass

The Financial Times reported on 27 October 2026 on talks about Russian business for American oil companies as part of the Ukraine negotiations. Such a prospect also affects Swiss commodities trading. It does not yet mean, however, that a company in Geneva could buy, finance or ship Russian oil as a matter of course. What continues to count are the rules actually in force and the specific transaction.

The publicly visible FT headline describes talks, not a completed general opening of the market. Details about the companies involved or contractual terms cannot be reliably determined from it. For the Swiss assessment, a different, verifiable question is therefore more useful: which decisions would have to lie between a political announcement and a permissible delivery?

Washington does not decide on Swiss bans

In the US, the sanctions authority OFAC can authorise certain otherwise prohibited transactions through general or individual licences. Such licences come with conditions and a defined scope. A permission for a specific transaction is not the same as lifting all sanctions against a country or a trading partner.

Switzerland, for its part, decides on its own measures. SECO explicitly states that even EU sanctions are not automatically adopted. Sanctions imposed by third states have in principle no direct effect here. The reverse limit follows from this as well: an American exemption does not replace a Swiss exemption and does not lift a Swiss ban.

That does not mean that foreign rules are unimportant for internationally active companies. It means first of all that different legal systems must be examined separately. An authorisation in one system does not answer all questions in the others. SECO, for its part, does not provide binding information on the legal systems of foreign states.

Destination and service change the assessment

The Swiss Ukraine ordinance distinguishes between several operations. Article 12a prohibits, under the conditions stated there, the purchase with destination Switzerland as well as the import, transit and transport of Russian crude oil and certain petroleum products into and through Switzerland. It also covers related services and funds. The article contains expressly regulated exceptions.

Article 12b, by contrast, concerns trade, brokering and transport with or to states outside Switzerland and the European Economic Area. Financial services may also be covered. Here the ordinance provides, among other things, for an exception if the purchase price does not exceed the relevant price cap. That is a different constellation from a delivery to Switzerland.

The price cap is therefore not a universal stamp of approval. In addition, bans may apply to specific companies, banks or ships. Article 12d, for example, contains separate restrictions for listed ships. A favourable purchase price alone does not answer these questions. Nor is it enough to know who sells the oil on paper.