Suspensions, EU sanctions regime, impact on residence rights.
Last reviewed
03.06.2026
Statute as of
24.02.2022 (V-Ukraine-Krieg in Kraft); fortlaufende Sanktionspakete bis 2026
Statute citations
7 linked
Reading time
21 min read
As of: 01.06.2026 · Snapshot
Russia and Belarus since 2022 — Impact of the sanctions regime on Swiss migration practice
Frequently asked
4 answers on this topic.
Concrete questions people ask about Russia · Belarus after 2022.
Switzerland adopted the EU sanctions regime (SECO ordinances). The visa facilitation agreement with Russia has been suspended (multi-stage visa procedure, longer processing times, higher fees). Personal sanctions (asset freeze, travel ban) apply to listed individuals. Existing permits remain valid in principle, unless personal sanctions apply.
Statute citations
7 statute citations, each linked directly.
01Reviewed: Tier A · Info
EmbG Embargogesetz (SR 946.231) — VERIFY exact ELI URI
: the sanctions packages and the SEM practice up to 18.05.2026 are taken into account.
Status
: AI draft, pending review by the supervising lawyer of record (CLR — Lawyer-of-Record). The subject matter is politically sensitive and subject to high volatility in terms of updates. Several factual issues are in the status
UNKNOWN per ADR-015 L14
and are marked as such in the text.
This post summarises the immigration law situation for Russian and Belarusian nationals in Switzerland following the start of the Russian full-scale invasion of Ukraine on 24 February 2022. Swiss practice is characterised by a dual approach: on the one hand, the adoption of EU sanctions packages via the Embargo Act, with implications for entry and asset-related issues; on the other hand, the asylum law assessment of politically persecuted or conscripted Russian and Belarusian nationals. A comprehensive special practice in the form of a codified special regime does not exist – as far as is publicly available; much of it can be found in scattered SEM directives, SECO lists and individual decisions of the FAC.
1. Overview — What has changed since 24 February 2022
With the start of the Russian full-scale invasion of Ukraine on 24 February 2022, Switzerland adapted its traditional practice with regard to EU sanctions regimes. Although the Federal Council initially reacted cautiously, on 28 February 2022 it decided to fully adopt the EU sanctions packages against the Russian Federation. This adoption is implemented from a legal point of view via the Embargo Act (EmbG, SR 946.231) and is specified in terms of content in the Ordinance on Measures in Connection with the Situation in Ukraine (hereinafter V-Ukraine-Krieg, SR 946.231.176.72 — the exact ELI-URI must be verified before productive use).
This has several implications for immigration law practice:
Existing permits remain unaffected — the sanctions mechanism does not target the ordinary immigration permit system, but rather entry bans for listed persons and economic restrictions.
New applications tend to be subject to stricter scrutiny — an increased level of scrutiny has been observed in practice, even though no publicly available SEM directive exists for Russian or Belarusian nationals (status UNKNOWN per ADR-015 L14, see section 14).
Asylum system to adopt new profile — the recognition of Russian conscripts and Belarusian protesters as politically persecuted persons is shifting the quotas compared to the pre-2022 period (exact 2026 figures: VERIFY).
Visa restrictions — the standard Schengen visa practice has become considerably more restrictive towards Russian nationals; the EU-Russia visa facilitation agreement was suspended by the EU in September 2022, and Switzerland has followed suit (VERIFY exact ELI/date).
Belarus is systematically included in this analysis because the sanctions mechanism is designed in a similar way (through a separate regulation) and asylum law practice has developed similarly since the protests of August 2020. Where Russia and Belarus differ, this is explicitly stated.
2. Legal basis
The immigration-related relevance of sanctions arises from several layers of law that interact with each other:
2.1 Embargo Act (EmbG, SR 946.231)
The Embargo Act of 22 March 2002 empowers the Federal Council to order coercive measures. Verbatim Art. 1 para. 1 EmbG:
“Measures aimed at preventing serious violations of international law may be ordered by the Federal Council.”
The Federal Council can order these coercive measures autonomously or in the form of adopting international sanctions imposed by third parties (in particular the EU or the UN). All post-2022 sanctions ordinances against Russia and Belarus are based on this. VERIFY the exact wording of Art. 1 EmbG in the consolidated version of 2026.
2.2 V-Ukraine War (SR 946.231.176.72)
The Ordinance on Measures in Connection with the Situation in Ukraine is the key instrument in migration law. It lists the individuals subject to sanctions, who are subject to an entry ban in Switzerland and the Schengen area, and orders the financial restrictions (freezing of assets, prohibition of economic transactions). The annexes are updated with each new round of EU sanctions – typically within a few working days of the EU adjustment.
2.3 AsylA (SR 142.31) and LEI/LStrI/FNIA (SR 142.20)
The ordinary Asylum Act and the Federal Act on Foreign Nationals and Integration constitute the legal framework within which the assessment of immigration law actually takes place. There is no separate lex specialis for Russian or Belarusian nationals in the AsylA or the Ausländer- und Integrationsgesetz; the SEM’s practice and the FAC’s case law operate within the general framework, with evidence assessed in a manner tailored to specific countries.
2.4 NDB Situation Report (VBS)
The annual report on the situation by the Federal Intelligence Service (NDB, Department of Defence) is not a legal act, but since 2022 it has contained increasingly explicit statements on the espionage and threat environment posed by Russia. The 2025 situation report indicates a "threat density never before experienced" (VERIFY exact wording and year of publication). This assessment indirectly influences the background checks carried out when issuing permits and granting naturalisation, without this being codified in a public directive (status UNKNOWN per ADR-015 L14).
3. Packages of sanctions — phasing 2022 to 2026
Since February 2022, the EU has adopted a series of sanctions packages. As of 18 May 2026, 16 or more packages are in force (accurate count VERIFY, as the EU Commission handles the numbering inconsistently). Each package typically includes:
Personal sanctions involving a ban on entry into the Schengen area and the freezing of assets.
Restrictions on the provision of services by Swiss companies to sanctioned entities.
Switzerland typically adopts the packages by means of an ordinance within a few days to a few weeks after the EU adoption. A complete verbatim adoption is the rule; specific adjustments are made where Swiss procedural law differs (for example, in the appeal procedure against listing).
For the purposes of immigration law practice, the following are relevant:
The consolidated list of persons of the SECO (in parallel to the EU consolidation) — this list is publicly accessible and contains the natural and legal persons subject to entry bans and asset freezes.
The annexes to the V-Ukraine-War ordinance, detailing the respective groups of people affected, sectors and exemptions.
Specific lists are not printed here because they are updated weekly or more frequently. The most up-to-date version can be accessed via the SECO website linked in the source information; effective use of this document requires checking it against the latest version.
4. Impact on Russian and Belarusian nationals in Switzerland
In immigration law practice, four different scenarios can be identified, each of which has a fundamentally different legal status.
4.1 Holders of permits issued before 2022
Russian and Belarusian nationals who were resident in Switzerland before 24 February 2022 and hold a valid AIG permit (B, C, L, G – third-country nationals regime) will retain their permits unchanged. No revocation will take place on account of sanctions, unless the person concerned is themselves on the SECO sanctions list.
Points to note in practice:
Extension and renewal procedures are being handled correctly; the cantonal migration offices are not subject to any specific instruction to treat these procedures differently in the case of Russian or Belarusian nationals.
Background checks have effectively been tightened (in the context of the NDB situation report), but are not publicly codified as a special regime (status UNKNOWN per ADR-015 L14).
Existing C permits (settlement) are particularly robust – a revocation based solely on nationality is not legally justified.
4.2 Applications submitted after 2022
Persons who apply for a residence permit in Switzerland for the first time after 24 February 2022 are experiencing stricter scrutiny in practice. This particularly affects:
Authorisation to work under AIG Art. 18-21 (employment of nationals of third countries) — stricter assessment of the employer’s proof of priority for Swiss or other EU/EFTA nationals.
Residence without gainful employment under AIG Art. 28 (pensioners) — stricter assessment of financial circumstances and the origin of funds in view of the sanctions regime.
Family reunification (see section 9) — additional obstacles in the granting of visas in the country of origin.
A formalised special procedure for Russian or Belarusian applicants is — as far as publicly available information shows — not known (status UNKNOWN per ADR-015 L14). The tightening of practice results from the general background check in the context of the NDB situation report.
4.3 Persons on sanctions lists
Anyone on the annex list of the V-Ukraine-War sanctions is subject to an entry ban to Switzerland and the Schengen area, and any assets located in Switzerland are frozen. Existing permits held by these individuals will be revoked or suspended (VERIFY the exact legal consequences — the ordinance contains references to the Federal Act on Foreign Nationals and Integration, and the specific implementation procedures are set out in the SEM guidelines, some of which are not publicly available).
A verification procedure exists for individuals who have been listed in error; an application for removal should be addressed to the SECO, with an appeal to the Federal Administrative Court. VERIFY the current procedure in 2026.
4.4 Tourist visas and short stays
The standard Schengen visa practice towards Russian nationals has become considerably more restrictive since the suspension of the EU-Russia visa facilitation agreement in September 2022. Switzerland is following the EU’s approach:
Higher visa fees (EUR 80 instead of EUR 35).
Longer processing times and stricter document checks.
Lower willingness of consular representations to grant multiple entry visas.
For Belarusian nationals, the practice is similar, although – as far as can be observed – somewhat less restrictive. VERIFY the current visa policy for 2026, as this data is among the most volatile information in the entire article.
5. Asylum applications by Russian and Belarusian nationals
Since 2022, a significant increase in asylum applications from Russia and Belarus has been recorded. The exact figures for 2026 are available in the SEM asylum statistics, which are referenced here (but not fixed) — VERIFY before using in production.
5.1 Recognition rates and grounds for asylum
The recognition rate for Russian and Belarusian asylum applications has been higher since 2022 than in the previous period. The typical reason for recognition is:
Political persecution (AsylA Art. 3) — in cases of demonstrated opposition, journalism or human rights activities.
Conscientious objection with political connotations — in the case of Russian reservists or conscripts who demonstrably reject the war of aggression (see section 7).
Collective punishment scenarios — Family members of persecuted activists.
A systematic presentation of the terminology relating to asylum law can be found in framework/fw_asylg_glossary.md.
5.2 Belarusian post-2020 protesters
Following the mass protests in Belarus from August 2020 onwards, the practice of recognising applications from Belarusian applicants with documented participation in the protests has become significantly more open. Leading decisions of the FAC have confirmed the persecutory nature of Lukashenko’s repressive practices; specific case numbers and dates can be found in the file framework/fw_asylg_glossary.md (VERIFY the current list there).
5.3 Duration of the procedure and status during the procedure
During the ongoing asylum procedure, the N permit (asylum-seeker permit) is issued — see permits/permit_n_asylum_pending.md. If the asylum application is approved, the B permit with asylum status (recognition as a refugee) is issued — see permits/permit_a_recognised_refugee.md. If the asylum application is rejected, but there are obstacles to enforcement, provisional admission (permit F) may be granted — see permits/permit_f_provisional_admission.md.
6. Persons on sanctions lists — procedures and legal protection
The inclusion of a natural or legal person on the annexes of the V-Ukraine-War sanctions list is an administrative measure with the character of an administrative ruling. It generally follows the EU listing automatically (adoption of the EU list into the Swiss annex).
Legal protection:
Application for deletion to the SECO (or to the competent chamber of the EDA, depending on the circumstances — VERIFY).
Appeal to the Federal Administrative Court against the rejection of the application for deletion.
Mirroring procedure in the EU — deletion from the EU list typically leads to deletion from the Swiss list.
Consultancy mandate: Sanctions review proceedings are generally a separate area of specialisation and not a classic area of immigration law. A specialist law firm with expertise in sanctions and foreign trade law is required here. This contribution refers to the subject without providing advice on it (anti-scope, see section 16).
7. Reservists and deserters — asylum law assessment
Since the partial mobilisation of Russia in September 2022, the situation of the conscripted Russian reservist has become a common basis for asylum claims. Swiss practice differentiates:
Simple conscientious objection to military service is, according to established case law of the FAC, not a ground for asylum in the strict sense.
Refusal to perform military service in the context of an unlawful war of aggression may, however, establish grounds for refugee status, insofar as the threatened sanction (criminal proceedings, imprisonment) can be qualified as politically motivated persecution.
Documented call-up notices are a key piece of evidence; without them, it is more difficult to achieve recognition.
As far as can be ascertained, a consolidated FAC guideline on the status of Russian reservists is still under development. Several individual decisions confirm the recognition; a systematic list of the relevant case numbers is VERIFY in framework/fw_asylg_glossary.md.
For Belarusian deserters or conscientious objectors, this situation is less common (Belarus is not a party to the war to the same extent), but the analogous consideration applies if there is demonstrable political motivation.
8. Dual nationals and departure from Russia and Belarus
The departure from Russia and Belarus has become increasingly difficult since 2022. Practical aspects:
Commercial direct flights between Russia and Switzerland are suspended; the typical travel route now goes via Turkey or the United Arab Emirates (Istanbul, Dubai, Abu Dhabi) as a hub.
Renewing a passport at a Russian or Belarusian embassy abroad is administratively complex and, in some cases (political activity, open criminal proceedings in the country of origin), practically impossible.
Dual nationals with an additional EU or non-EU nationality have a significantly easier time — entry is made using the non-EU passport, and the visa regime applies accordingly.
Sole Russian or Belarusian nationality without any other passport is the most difficult scenario; a travel document for foreign nationals under FNIA Art. 59 can be applied for after the permit has been granted, in order to reduce the dependence on a national passport. VERIFY the current SEM practice in 2026 regarding the issuance of these documents to Russian and Belarusian nationals.
9. Family reunification for Russian and Belarusian nationals
Family reunification is governed by the ordinary provisions of the AIG (Art. 42 ff. AIG). The sanctions mechanism does not directly affect these provisions, but it does influence their implementation:
9.1 Holders of permits issued before 2022
Anyone who, as a Russian or Belarusian national, received a B or C permit before 24.02.2022 can apply for family reunification in the ordinary manner, in accordance with AIG Art. 43 (for C) and Art. 44 (for B). The requirements (joint accommodation, secure means of support, no dependence on social welfare, sufficient knowledge of German/French/Italian, depending on the circumstances) apply as usual.
9.2 Applications submitted after 2022
In the case of new applications, the requirements are examined more rigorously, in particular:
Social welfare condition — the provision of means of support is documented in more detail.
Proof of income — in the case of income originating from Russia, additional compliance checks will be carried out (to ensure that payment flows comply with sanctions).
Source of funds — in the case of assets, compliance with the sanctions regime is checked.
9.3 Visa issuance in the country of origin
Even with a positive preliminary decision from the cantonal migration office, obtaining a visa at the Swiss embassy in Moscow or Minsk is proving difficult in practice. Consular representations are applying the more restrictive post-2022 standard. Precise processing times and exclusion quotas: VERIFY.
10. Naturalisation of Russian and Belarusian nationals
The standard requirements of the Swiss Citizenship Act (Bundesgesetz über das Schweizer Bürgerrecht, SR 141.0) apply to Russian and Belarusian applicants without change – see permits/permit_naturalisation_paths.md and framework/fw_bug_2018_glossary.md. Any tightening or easing of requirements due to sanctions is not provided for in law.
Practical observations:
Background checks are handled more thoroughly in the context of the NDB situation report — the requirements for evidence of political distance from the country of origin have increased in practice (status UNKNOWN per ADR-015 L14 — no publicly available SEM special instruction).
The duration of the procedure is slightly longer in some cantons than the average for comparable third-country nationals.
Rejection based solely on nationality is not legally permissible – the SCA does not provide for a nationality filter.
11. Return to Russia or Belarus
The return to the country of origin is practically difficult for several categories of people:
Recognised refugees (B permit with asylum grounds, permit A) typically lose their refugee status upon returning – even for a short visit – as the need for protection is implicitly deemed to have ceased. VERIFY the SEM’s practice regarding tolerance for short humanitarian stays.
F permit holders (provisional admission) are subject to similar restrictions – their return to their country of origin raises the question of whether the obstacles to enforcement will cease to apply.
Holders of ordinary B or C permits who do not have grounds for asylum can, in principle, travel freely; the political risk situation upon return (arrest of political activists, mobilisation) is a separate issue for consideration outside the narrower framework of immigration law.
11.1 REAG and GARP programmes
The REAG return assistance (reintegration assistance programme) and the GARP programme (Government Assisted Return Programme) of the Swiss authorities are available to recognised refugees and those granted provisional admission who wish to return voluntarily. These programmes are not accessible to holders of permits only who do not have grounds for asylum. Specific conditions and 2026 amounts: VERIFY.
12. Tax and Banking Aspects — Interface without Advice
Three interfaces are frequently encountered in immigration law advice, but they do not fall within the scope of this platform's advisory services (out of scope, see section 16):
Double Taxation Agreement (DTA) between Switzerland and Russia: According to publicly available information, the DTA is still formally in force; however, individual provisions have been suspended or are not being applied in practice in light of the sanctions. VERIFY the status as of 2026. A separate DTA is in force for Belarus (VERIFY).
Swiss banking transactions: Swiss banks have introduced enhanced KYC processes for Russian and Belarusian clients. Opening new accounts has become more difficult, and existing accounts are subject to increased compliance requirements.
Asset transfers: Money flows from Russia to Switzerland are subject to full sanctions compliance checks; in many cases, a transfer is practically impossible.
These topics are not covered by SwissImmigrationPro — they fall within the remit of tax advisory services, bank advisory services and sanctions/compliance legal counsel (see section 16).
13. NDB Situation Report and Background Check
The NDB Situation Report (annual publication of the Federal Intelligence Service) has significantly increased the threat assessment regarding Russia and China since 2022. The 2025 Situation Report indicates, according to publicly available reports, a “threat density never before experienced” (VERIFY the exact wording and year of publication – the report is typically published in May/June each year and covers the previous year).
For the practical application of immigration law, this means:
Enhanced background check carried out by the SEM, cantonal migration offices and, where applicable, Fedpol in the case of initial applications and naturalisations.
Extended processing times in cases involving security-related issues.
No publicly available specific instruction — the specific review standards do not appear to be codified in a public ruling (status UNKNOWN per ADR-015 L14).
A consolidated overview of the SEM directives — to the extent that they are publicly available — can be found in framework/fw_sem_directives_index.md.
14. What is unknown — transparency according to ADR-015 L14
In line with the transparency requirements set out in ADR-015 L14, the following issues are explicitly identified as UNKNOWN – they have not been verified, codified or made reliably available to the public:
Existence of an explicit SEM instruction for the treatment of Russian and Belarusian applicants in the manner of a codified enhanced-scrutiny procedure — as far as can be seen, not publicly published; possibly only for internal use.
Current 2026 recognition rates for Russian and Belarusian asylum applications — verifiable via the SEM asylum statistics, but volatile as a snapshot; not fixed in this article.
Specific background check standards for NDB/Fedpol involvement in permit and naturalisation procedures — probably classified or for internal administrative use only; not publicly available.
Exact number of EU sanctions packages as of the reference date – the method of counting is inconsistent; “16+” is the conservative estimate.
Current SEM special practice for nationals of Russia or Belarus who have been resident in Switzerland before 2022 when renewing their permits — no discernible official instruction, but in practice, it is a standard procedure.
Enforcement pathway in the event of a person being listed, in relation to a permit card issued in Switzerland — the legal consequences (revocation, suspension, withdrawal) are not clearly codified.
Application of the Russia Double Taxation Agreement in light of the sanctions — formally in force, but the actual scope of application is unclear.
This list is not exhaustive; it indicates the knowledge gaps identified at the time this document was created. It will be updated each time a refresh is triggered.
15. References and Cross-Links
The following contributions from the SwissImmigrationPro platform are related to this contribution:
framework/fw_asylg_glossary.md — Glossary of the Asylum Act, recognition practice, key decisions of the Federal Administrative Court.
framework/fw_aig_vzae_glossary.md — Third-country nationals regime under the FNIA, requirements for B, L, G and C permits.
framework/fw_sem_directives_index.md — Index of publicly available SEM directives.
framework/fw_bug_2018_glossary.md — Swiss Citizenship Act, requirements for naturalisation.
framework/fw_data_protection_ndsg.md — Data protection in immigration proceedings.
permits/permit_n_asylum_pending.md — Status during asylum proceedings.
permits/permit_a_recognised_refugee.md — Status after asylum has been granted.
permits/permit_f_provisional_admission.md — Provisional admission in the event of obstacles to enforcement.
permits/permit_b_resident.md — Third-state B residence permit.
permits/permit_c_settled.md — C settlement permit.
permits/permit_s_ukraine_temporary_protection.md — Comparable politically motivated special measure (for Ukrainian nationals).
bilaterals/bi_uk_post_brexit_citizens_rights.md — Comparable bilateral adjustment of practice following a political event (Brexit), as a methodological reference for the interweaving of international and migration law practice.
16. Anti-Scope — What this contribution does not achieve
A politically sensitive topic such as the Russia/Belarus sanctions regime is prone to misunderstandings regarding the scope of the advice provided. This article therefore clearly defines its scope:
No advice on circumventing sanctions: Strategies to circumvent the V-Ukraine-war sanctions are not covered and will not be provided, even in individual lawyer-client mandates. Circumventing sanctions is a criminal and administrative offence under Swiss law.
No asylum strategy advice: This post explains the legal framework, not the individual tactical strategy for maximising the chances of an asylum application being accepted. Such a mandate falls within the remit of specialist asylum lawyers registered on the cantonal bar register.
No banking or compliance advice: KYC issues, account opening strategies and bank compliance fall within the remit of banking and compliance lawyers, as well as the banks themselves.
No tax advice: The application of double taxation agreements, international asset structures and tax planning relating to residence are not covered by this platform.
No political statement: This contribution describes the current law and practice, without any political assessment of the sanctions policy or the geopolitical events underlying it. The use of this content for political argumentation purposes is not intended.
For individual cases, it is advisable to engage a migration lawyer registered in the cantonal bar register — and, depending on the circumstances, also a specialist sanctions and foreign trade law lawyer, as the two areas of specialisation are practically distinct.
This entry will be updated with each new sanctions package, each published SEM directive and each relevant FAC leading decision. The volatile nature of the subject matter requires a stale-threshold SLA of 60 days instead of the usual 90 days.
As of: 01.06.2026 · Snapshot
Reflects the cited law as of the snapshot — not a check of current force.
