Sanctions compliance: tasks, roles and capacity when new packages land

Short answer: After a new sanctions package, companies must update their screening lists within a few days, check customers, suppliers and live business against the new listings and restrictions, stop affected deliveries and payments and document every decision. In the EU, a package applies once the Council regulations enter into force, for the 21st Russia package from 24 July 2026. Switzerland does not adopt EU sanctions automatically; it decides on each package separately and usually with a delay through the Ukraine Ordinance (SR 946.231.176.72). The listings of the 21st package have applied in Switzerland since 11 August 2026 (11 pm).

This guide is for heads of compliance, trade compliance leads and legal departments in industry, trade and financial institutions in Switzerland and Germany. It sets out the sanctions compliance tasks in the first ten days after a package and the roles that can be reinforced on an interim basis.

How the EU and Switzerland adopt sanctions

The EU adopts Russia sanctions as Council regulations that apply directly in all member states; Switzerland decides itself on the basis of its Embargo Act (EmbA, SR 946.231). The differences determine when each entity in a group has to act.

The 2026 packages at a glance

• 21st EU package (23 July 2026): 218 new listings, transaction bans for more than 100 Russian banks, a ban on crypto services from third countries, 51 further anti-circumvention entries, 41 shadow fleet vessels and enhanced legal protection tools for EU companies (including Regulations (EU) 2026/1848 and 2026/1844).
• Listing package of 12 October 2026: by number of new listings, the Council adopted its largest listing package to date: 1,569 new entries (743 individuals, 826 companies) from the military-industrial complex (Implementing Regulation (EU) 2026/2281). The regulation only extends the sanctions list in Annex I to Regulation (EU) No 269/2014 and contains no new trade, financial or energy restrictions.
• Switzerland: the decision in principle to adopt EU sanctions was taken on 28 February 2022. On 19 August 2026, the Federal Council adopted further measures from the 20th package, including the first use of the anti-circumvention tool (export ban on certain goods to Kyrgyzstan), a ban on Russian crypto platforms and service bans in the LNG sector. Around 2,790 individuals and organisations are subject to asset freezes in Switzerland. According to our information as at October 2026, Switzerland had adopted only the listings from the 21st package; no decision had yet been taken on its financial, energy and trade measures.

The first ten days after a new package

The first ten days decide whether a company implements a new package in a controlled way. The plan below is a practical example, not a statutory deadline; what counts is always the entry into force of the relevant regulation.

Groups with entities in the EU and in Switzerland often face a gap: the EU package already applies while Swiss adoption follows weeks later. The group policy should state how the Swiss entity handles business already prohibited in the EU during that period.

Screening, contracts, supply chain, payments

Sanctions compliance covers four areas that must be adjusted at the same time after every package.

• Screening: the core is the prohibition on making funds available: no funds or economic resources may be made available to listed persons (Art. 2 Regulation 269/2014). This includes checking the ownership and control of business partners, not just matching names.
• Contracts: review sanctions clauses and termination and suspension rights, and add them to new contracts. For exits from Russia, EU law provides time-limited derogations that must be applied for case by case with the competent authority; check the current deadlines in the applicable regulation before any exit.
• Supply chain: check goods lists, end use and circumvention risks via third countries; Switzerland activated the anti-circumvention tool for the first time for Kyrgyzstan. Since the 21st package, the EU also has reporting duties in the LNG sector.
• Payments: implement transaction bans with listed banks. In Switzerland, financial intermediaries must freeze assets of listed persons and report them to SECO; this report replaces neither the clarifications under Art. 6 of the Swiss Anti-Money Laundering Act nor a report to MROS, the Money Laundering Reporting Office, under Art. 9 of that Act.

For financial institutions the topic carries extra weight: FINMA lists sanctions among the nine main risks in its Risk Monitor 2025, and the draft partial revision of the FINMA Anti-Money Laundering Ordinance provides for more concrete measures against breaches of embargo measures. Our guide to interim legal and compliance for banks covers typical bank projects.

Roles: screening analyst, trade compliance manager, lawyer

A new package creates a workload peak of a few weeks that the permanent team rarely covers alone. Three roles can be reinforced on an interim basis:

• Screening analysts (junior to experienced): re-screening, resolving hits, ownership and control analysis, documentation. For large portfolios, as a taskforce with a team lead.
• Trade compliance managers (experienced to senior): goods classification, export control, review of orders and supply chains, liaison with logistics and sales.
• Sanctions lawyers (senior): interpreting the package, exemptions and authorisations, contract questions, papers for management.

Alpinum Solutions provides these roles through staff leasing or freelancing, part-time or full-time, as individuals or as a taskforce. Under staff leasing, the company directs the work; under freelancing, the professional works independently within the mandate. Selected profiles are usually available within 48 hours; the company and Alpinum agree the start date together. For ongoing compliance work alongside the sanctions project, see interim compliance.

Limits and risks

The duty to comply with sanctions lies with the company and the individuals acting for it. Interim professionals work within the company's instructions and approval routes; decisions on frozen assets, terminations and licence applications stay with management and the compliance function. Alpinum is not a law firm. Where ownership structures are unclear or amounts are high, external legal advice makes sense. Access to screening systems and customer data should be settled before the start.

Frequently asked questions about sanctions compliance

Does Switzerland adopt EU sanctions automatically?

No. On the basis of its Embargo Act, Switzerland decides on each EU package separately, in full or in part and usually with a delay. Implementation is through the Ukraine Ordinance, and SECO is responsible for enforcement. Listings often come first, with financial, trade and energy measures following later. Until adoption, the previous position applies in Switzerland.

Who is liable for sanctions breaches?

In Germany, section 18(1) of the Foreign Trade and Payments Act (AWG) provides for imprisonment of three months to five years for breaching directly applicable EU sanctions provisions, such as the prohibition on making funds available. Negligent breaches are administrative offences (section 19(1) AWG), and fines against the company are possible under sections 30 and 130 of the Administrative Offences Act (OWiG). In Switzerland, anyone who intentionally breaches sanctions ordinance provisions declared punishable faces imprisonment of up to one year or a monetary penalty, and up to five years in serious cases; negligent breaches are fined up to CHF 100,000 (Art. 9 of the Embargo Act, EmbG). Other contraventions, such as refusing to provide information, are covered by Art. 10 EmbG.

How quickly does Switzerland adopt an EU package?

It varies. The listings of the 21st EU package of 23 July 2026 have applied in Switzerland since 11 August 2026. Switzerland had not adopted the EU listings of 12 October 2026 as at 31 October 2026. The further measures of the 20th package, which the EU adopted on 23 April 2026, were implemented by the Federal Council from 20 August 2026. Companies should therefore follow announcements from SECO and the Federal Council continuously.

What is the difference between listings and sectoral measures?

Listings target specific individuals and organisations: their assets are frozen and no funds or economic resources may be made available to them. Sectoral measures restrict entire areas, such as trade in certain goods, financial services, crypto services or LNG services. Listings mainly require screening; sectoral measures require reviews of contracts and supply chains.

Do banks also have to report hits to MROS?

Freezing and reporting to SECO is a separate duty. It replaces neither the special clarifications under Art. 6 of the Swiss Anti-Money Laundering Act nor a suspicious activity report to the Money Laundering Reporting Office (MROS) under Art. 9 of that Act. The financial intermediary therefore assesses separately, under anti-money laundering law, whether an MROS report is required.

Next step

Tell us about your portfolio, business model and the countries involved. We will show you suitable profiles for screening, trade compliance or legal support for the next package.

• Sanctions, trade compliance and export control
• Interim compliance
• Regulatory calendar for legal and compliance
• Discuss your requirements

Last updated: 31 October 2026.