On May 22, 2026, two governments revealed, on the same day, how badly sanctions design and semiconductor supply chains are colliding. Switzerland's State Secretariat for Economic Affairs (SECO) expanded its Russia and Belarus sanctions lists to align with most of the EU's 20th sanctions package — 115 new individuals and entities under asset freezes, 60 companies facing tighter export controls, 46 vessels blacklisted, and a transaction ban on 20 Russian banks plus seven third-country financial intermediaries. But Bern deliberately left seven other third-country companies off its list despite the EU having designated them, and shelved the package's financial-, energy- and trade-sector measures for later review — a gap Baker McKenzie's sanctions tracking blog says is now a pattern, not an anomaly, with Swiss implementation running weeks to months behind Brussels.
Hours later, the European Commission did something that looks like the mirror image: it proposed a nine-month derogation letting EU companies keep dealing with Yangzhou Yangjie Electronic Technology — the Chinese power-semiconductor maker Brussels had itself sanctioned on April 23, 2026 as part of the same 20th package, for allegedly supplying dual-use components later found in Russian drones and glide bombs. The proposed carve-out, reported by Global Banking and Finance, would let EU operators wind down existing Yangjie contracts through December 31, 2026, and buy critical components while they scramble for alternative suppliers. It requires unanimous sign-off from all 27 member states.
Why Yangjie, and Why Now
The reason the EU is unwinding its own ban six weeks after imposing it traces back to the Netherlands. On September 30, 2025, the Dutch government invoked its Goods Availability Act to seize operational control of Nexperia, the chipmaker owned by China's Wingtech, citing governance failures that it said threatened European access to critical chip technology. Beijing retaliated on October 4 with export controls blocking Nexperia's China-made output, triggering production stoppages at automakers across Europe. In the scramble that followed, Yangzhou Yangjie — a maker of rectifiers, MOSFETs, IGBTs and silicon-carbide devices, not cutting-edge logic chips, but foundational parts for every vehicle's power electronics — became the default replacement supplier. Six months later, the EU sanctioned that same company, and automakers warned inventories would run dry within weeks.
The Case for Sticking to the List
There's a serious argument for holding the line on both sides. Sanctions regimes work only when circumvention routes stay closed — every company or country that gets a pass becomes a laundering point, and Russia's shadow-fleet and shadow-supplier networks exist precisely to exploit those gaps. Switzerland's history as a financial and trading hub gives it particular reason to avoid looking selective, and a Commission that carves out exceptions within weeks of imposing them risks teaching sanctioned entities that EU listings are negotiable if the economic pressure is loud enough. If Yangjie really did route more than 200 dual-use shipments toward Russia's military-industrial complex, as EU officials allege, a nine-month reprieve is nine more months of exposure.
But This Is What Proportionate Enforcement Looks Like
That argument proves too much. A sanctions list assembled without an impact assessment on the EU's own industrial base was always going to produce exactly this outcome — banning the company that had just become Europe's emergency backup supplier, discovered only after automakers started warning of shutdowns. The Commission's derogation isn't a retreat from sanctions; it's a correction for a listing process that moved faster than the due diligence needed to understand its second-order effects. A wind-down window tied to a hard December 31 deadline, requiring unanimous member-state approval, is a narrowly tailored fix — not an open door.
Switzerland's sequencing looks more defensible than its critics suggest, too. Publishing asset freezes and travel bans immediately while taking more time on trade- and financial-sector measures that touch actual commercial relationships is a reasonable division of labor between the parts of a sanctions package that are politically urgent and the parts that require legal and economic scrutiny to avoid overreach. Bern's unexplained decision to omit seven specific companies is a legitimate transparency complaint — SECO owes the public, and its EU partners, a fuller account of why. But that is a narrower failure than the alternative both governments are visibly trying to avoid: sanctions regimes so blunt they have to be rewritten within weeks of taking effect, at the cost of the very industries — and workers — regulators are supposed to be protecting.
The lesson from May 22 isn't that either government lacks resolve. It's that sanctions targeting semiconductor supply chains, where a handful of Chinese and third-country suppliers occupy chokepoints for the whole European auto industry, need the same kind of impact modeling that export-control regimes for advanced chips have slowly built up since 2022. Speed and precision are in tension here, and both Brussels and Bern just found out which one loses when they aren't reconciled in advance.