Only bank deposits of at least 100,000 francs are subject to reporting rules, the State Secretariat for Economic Affairs, the agency overseeing sanctions, said.
And Russians who are also Swiss or European Union citizens, or living in Switzerland legally, also fall outside the sanctions regime, a secretariat spokesman told Law360.
"Every Swiss franc in Switzerland that is under the control of a sanctioned person is now announced to us in SECO so that there is no more money left that can be announced," the spokesman said.
"There is a lot of legal money of Russian persons in Switzerland, as in every other country in Europe, [but] there is no consequence because it's legal money," he added.
Some 7.5 billion francs in financial assets and 15 properties held by sanctioned natural persons, companies and entities were frozen in Switzerland by Nov. 25.
The Swiss Federal Council decided on Feb. 28 to adopt the European Union's sanctions against Russia in response to the invasion of Ukraine. The rules block countries from accepting deposits from Russians and legal entities from the country if deposits are worth more than the equivalent of 100,000 francs per person.
The European Commission has toughened its position on the war, rolling out plans to create a new structure to manage frozen and immobilized public Russian assets, invest them and use the proceeds for the postwar reconstruction of Ukraine.
The commission said this week that it is considering whether to invest €319 billion ($334 billion) of frozen Russian assets to help pay for the damage caused by the Kremlin's invasion of Ukraine.
The United Nations estimated in September that more than 14,000 people have been killed in the conflict, but warned that the true numbers are most "likely considerably higher."
--Editing by Ed Harris.
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