How Can Individuals Be Removed From Swiss Sanctions List?

1. What is the purpose of the Swiss economic sanctions policy? How can persons be removed from the Swiss Sanctions list?
The primary objective of Switzerland imposing sanctions on a legal entity or an individual is to encourage to change behavior in line with the Swiss policy goals by that persons and companies. Economic sanctions are to be distinguished from criminal punishment. Accordingly, if it can be shown that the basis for the designation no longer applies, potentially the behavior may have already been changed at the time the sanctions have been imposed and respectively at the time that the person or company has been included in a sanctions list, the relevant person or company has to be removed from the Swiss sanctions list. Successful cases of removal are typically businesspeople that do not or no longer support certain government activities, as well as family members or known contacts that do not or no longer support sanctioned actors.

2. Are law firms allowed to represent clients?
LINDEMANNLAW is a Swiss law firm acting under the laws of the Swiss Confederation. While the Swiss Confederation has taken to implement Swiss economic sanctions in harmony with the EU, Swiss law firms for sanctions removal are not prohibited to provide legal services to Russian individuals¹. Swiss law firms are also allowed to provide legal services to Russian legal entities with respect to judicial, administrative or arbitral proceedings to maintain their access to justice.

3. Are all persons on the EU sanctions list also on the Swiss sanctions list?
It is possible that individuals were not placed on the list by the EU as part of the sanctions against Russia, but rather as part of other independent sanctions regimes. The Federal Council is aware of this. These so-called "thematic" sanctions regimes are not directed against an individual country but are intended to target certain types of behavior worldwide (human rights violations, cyberattacks and the use of chemical weapons). In addition to Russian individuals and legal entities, individuals and legal entities from a large number of other countries are also targeted by the sanctions, including North Korea, China, Libya and Eritrea. Accordingly, these thematic sanctions must be clearly distinguished from the sanctions implemented as a result of measures taken in connection with the situation in Ukraine. The listings of Russian individuals and legal entities were made by the EU independently and well before the current conflict.

6. What are the benefits of a removal from the Swiss sanctions list?
The mayor benefit is asset unfreezing after Swiss sanctions removal. The former designated person can freely manage all his or her assets. Especially bank accounts will be deblocked. In addition, the assets of companies controlled by the former designated person are unfrozen and can be used to conduct business.