Switzerland – Page 2 – European Sanctions Enforcement

May 10, 2024 by Mark Handley

Switzerland – publishing the 10 fines for breaching Russian and Belarusian sanctions imposed by SECO: an introduction

Today we start a series of posts in which we will be publishing anonymized versions of the ten final administrative criminal decisions issued by SECO as part of proceedings for breaching Russian, and Belarusian, sanctions in Switzerland.

The details of these proceedings, the conduct giving rise to the fines, the process of the investigations, and the level of the fines are all not otherwise public.

These anonymized final decisions have been obtained through a Freedom of Information request to SECO, and SECO has confirmed that these anonymized versions may be published or otherwise made available.

The blog is grateful for SECO’s assistance.

We will publish the first three decisions today, three more on Monday and the final four on Tuesday of next week.

As well as the final decisions themselves (some of which are in German and some in French), we will be publishing machine translations into English for convenience. We make no representation as to the accuracy of these translations. The blacked-out redacted text in the originals is shown as “REDACTED” in the translations.

April 22, 2024 by Mark Handley

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

March 15, 2024March 15, 2024 by Mark Handley

European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

Continue reading “European sanctions enforcement: the last two months”

March 13, 2024 by Mark Handley

Switzerland – a new criminal investigation for sanctions breaches and a further SECO fine

It is being reported today that the Office of the Attorney General of Switzerland has commenced a criminal prosecution in a case handed to it from SECO.

Neither the name of the company involved, nor the sector, nor the alleged offences have been made public.

It is also being reported that the Office of the Attorney General has rejected a second case referred to it by SECO.

The same report quotes SECO as saying that it has received 240 reports of possible sanctions breaches and had imposed 10 penalties. As in our earlier post , last month SECO was quoted as saying it had imposed 9 fines, indicating that a further fine has been imposed since. No further details are known of this fine.

February 21, 2024 by Mark Handley

Switzerland – updated enforcement statistics including 9 fines

Sanctions enforcement statistics for Switzerland’s SECO have been reported today. These are an update on those previously published in May last year.

- 230 reports to SECO of potential sanctions breaches:
- 47 proceedings commenced, of which:
  - 18 cases remain active;
  - 9 fines imposed; and
  - 20 cases discontinued.

SECO also stated that new cases are being added all the time, and that most relate to trade sanctions.

No information was published as to the level of the fines imposed (other than “varying severity”), or the identities of those fined or being investigated or prosecuted.

February 13, 2024 by Mark Handley

Switzerland – SECO refers two cases of breaching Russian sanctions for prosecution

It has been reported today that Switzerland’s State Secretariat for Economic Affairs (SECO) has referred two of its investigations into commodity trading companies to the Attorney General’s Office for criminal prosecution.

A third, allegedly similar, case is still being investigated and has not been referred.

It is reported that the allegations relate to the attempt to use of foreign subsidiaries to undertake trade in breach of the relevant Swiss sanctions against Russia.

July 4, 2023January 11, 2024 by Mark Handley

Switzerland – investigation into oil trading company

It has been reported that the Swiss authorities are currently investigating allegations that Paramount Energy & Commodities SA has been unlawfully trading oil of Russian origin through a Dubai-incorporated subsidiary in breach of the Swiss adoption of sanctions against Russia.

May 8, 2023January 11, 2024 by Mark Handley

Switzerland – revised enforcement statistics: 130 cases

Further to our earlier post that the Swiss had nearly 100 sanctions investigations, the Swiss authorities have provided an update.

The number of investigations conducted by SECO (the State Secretariat for Economic Affairs) is now 130, with 29 of those referred for criminal prosecution.

March 14, 2023January 11, 2024 by Mark Handley

Switzerland – nearly 100 criminal investigations for sanctions breaches

The Swiss authorities have this week provided some statistics on their ongoing sanctions enforcement efforts.

They have reported a total of 100 investigations. Of those:

- - 13 investigations have been concluded without charge;
  - 23 have had criminal proceedings commenced; and
  - 60 cases remain under investigation.

While most of these relate to Russia, at least two relate to Belarus sanctions.

The majority of the investigations are said to relate to trade sanctions rather than financial sanctions.

December 1, 2022January 11, 2024 by Mark Handley

Switzerland – 30 investigations into reporting failures

It was reported today that the Swiss authorities are currently investigating 30 possible breaches of frozen asset reporting under the Swiss sanctions against Russia.

It was also stated that one of these cases had already been referred to federal prosecutors.