Crypto & Digital Assets in Switzerland

Key dates

2026-11-03

The EAER expanded and amended the Swiss sanctions lists relating to Russia and Belarus.

2026-11-04

The Federal Council decided to adopt the EU’s 21st Russia and Belarus sanctions package and related measures.

2026-11-04

The amended sanctions lists entered into force at 23:00 Swiss time.

2026-11-05

The sectoral measures, including the strengthened crypto-sector restrictions and transaction prohibitions, entered into force.

Suggested considerations

• Compliance teams may wish to refresh sanctions screening against the amended Swiss Russia and Belarus lists, including customer, beneficial-owner, authorised-signatory, counterparty and payment screening records.
• Swiss crypto-sector companies should consider reviewing ownership registers, pending acquisitions, shareholder changes, control arrangements and beneficial-ownership information for Russian nationals and persons resident in Russia, including indirect acquisition structures.
• Firms should consider mapping exposure to the newly prohibited banks, financial institutions, crypto-service providers and other entities, and placing appropriate holds on affected transactions and assets pending resolution.
• Financial intermediaries may wish to document asset-freeze decisions and report affected business relationships to SECO in accordance with the applicable Ukraine sanctions ordinance.
• Where sanctions-related facts create suspicion of money laundering or terrorist financing, firms should consider completing the additional clarifications required by Article 6 AMLA and filing an immediate report under Article 9 AMLA if the suspicion cannot be dispelled.
• Firms may wish to update sanctions procedures, transaction-monitoring scenarios, onboarding questionnaires and escalation controls to distinguish SECO sanctions reporting from separate AMLA reporting.
• Compliance teams may wish to review external exposure to EU sanctions controls as well as Swiss measures; independent Swiss sanctions commentary describes the regime as not being a general Russia or Belarus embargo, but highlights continuing expansion of financial, crypto, services and circumvention controls.

What changed

The EAER expanded and amended the Russia and Belarus sanctions lists, adding 254 individuals, companies and organisations to measures including asset freezes and restrictions on making funds or economic resources available. Switzerland also introduced transaction prohibitions covering, among others, 33 Russian banks, one bank in a third country, 17 financial institutions and crypto-service providers, five third-country companies, four Russian airports and two Russian ports.

Key dates

2026-05-22

Switzerland added 115 natural persons and organisations to its Russia-related sanctions list; approximately 2,790 persons, companies, and organisations are now subject to asset freezes in connection with Russia’s war against Ukraine.

2026-08-19

The Federal Council decided to adopt the further measures of the EU’s 20th Russia sanctions package according to Switzerland’s established practice.

2026-08-20 Deadline

The new measures entered into force, including the prohibition on using Russian platforms for crypto-asset transfers and exchanges and the prohibition on supporting development of specified Russian crypto-assets such as the digital rouble.

Suggested considerations

• Firms should consider updating sanctions screening rules, prohibited-platform lists, wallet and counterparty controls, and transaction-monitoring scenarios to identify Russian crypto-asset platforms and indirect use of those platforms.
• Crypto-asset firms should consider mapping all transfer, exchange, custody, brokerage, technical-support, wallet-access, and infrastructure services against the applicable provisions of the Ordinance on Measures connected with the Situation in Ukraine, including the newly prohibited Russian platforms and specified Russian crypto-assets.
• Compliance teams may wish to review exposure to the digital rouble and other Russian or rouble-linked crypto-assets, including holdings, listings, liquidity provision, development support, transfers, and third-party integrations, and document any required exit or blocking decisions.
• Firms should consider validating that assets of sanctioned natural persons, companies, and organisations are blocked and that affected business relationships are reported to SECO in accordance with the sanctions ordinance.
• Firms should consider establishing or refreshing procedures for prompt escalation of sanctions-related suspicions, including additional clarifications under Article 6 GwG and an immediate Article 9 GwG report to the Money Laundering Reporting Office where suspicions cannot be dispelled.
• Senior compliance and operations owners may wish to evidence implementation from 2026-08-20 through control attestations, blocked-transaction testing, vendor and platform due diligence, and documented review of open Russian-related relationships.

What changed

The Switzerland-Russia sanctions regime now prohibits the use of Russian platforms for crypto-asset transfers and exchanges, targeting alternative payment channels that could facilitate sanctions circumvention. It also prohibits support for the development of specified Russian crypto-assets, including the digital rouble; independent market commentary places this measure alongside restrictions concerning Russian crypto-asset service providers, sanctioned trading venues, wallet or account access, technical assistance, and certain rouble-backed assets such as RUBx and A7A5, although the FINMA...

Key dates

2026-08-18

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland.

2026-08-19

SECO updated the SESAM database and published the Swiss sanctions-list adjustment.

2026-08-20

FINMA published the updated sanctions notice describing the amendment and related financial-intermediary obligations.

Suggested considerations

• Compliance teams may wish to obtain the 2026-08-19 SESAM update and identify precisely which persons, companies or organisations were added, amended or removed.
• Firms should consider refreshing sanctions-screening data and screening customers, beneficial owners, counterparties, payment parties, securities positions and existing business relationships against the amended entries without delay.
• Where a potential match is identified, firms should consider applying the relevant prohibitions, preventing disposal or transfer of assets, documenting the match analysis and escalating the case under their sanctions procedures.
• Firms should consider reporting affected business relationships and frozen assets to SECO in accordance with SR 946.231.08 and retaining evidence of the report and asset-freeze decision.
• A SECO sanctions report should not be treated as a substitute for AML controls; where indicators give rise to suspicion, compliance teams may wish to conduct the additional clarifications required by Article 6 GwG and file an immediate MROS report under Article 9 GwG if the suspicion cannot be dispelled.
• Firms with delegated or outsourced screening may wish to verify that vendors refreshed their Swiss sanctions data after 2026-08-19 and that payment and transaction-monitoring controls cover the amended list.

What changed

The sanctions list under the Swiss Ordinance of 2025-03-21 on measures against persons and organisations associated with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) was amended following the UN committee decision of 2026-08-18. The publication does not identify the amended entries or specify whether they are new designations, amendments or delistings; firms should therefore reconcile the current SESAM data against their prior screening population. The amendment applies in Switzerland directly and without a separate Swiss legislative adoption step.

Key dates

2026-08-14

The competent UN sanctions committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland under the applicable automatic-implementation framework.

2026-08-17

SECO updated the Swiss-authoritative SESAM sanctions database and published the corresponding list adjustment.

2026-08-19

FINMA published its notice reporting the SECO sanctions-list update.

Suggested considerations

• Compliance teams may wish to retrieve the 17 August 2026 SESAM update and reconcile it against the prior list, recording all additions, removals and amendments and preserving the source version used.
• Firms should consider rerunning customer, beneficial-owner, counterparty, payment, trade and custody screening against the amended list, including historical transactions and open orders where their risk-based controls require retrospective review.
• Firms should consider reviewing transliterations, aliases, dates of birth, nationality, incorporation data and other identifiers for any newly listed individual or entity to reduce false negatives and false positives.
• Where a potential match is identified, firms should consider applying the prohibitions and asset-freeze requirements under SR 946.231.08, escalating the case under their sanctions procedures and assessing whether notification to SECO is required.
• Compliance teams may wish to verify that vendor feeds, transaction-screening systems, watchlists, case-management workflows and manual escalation procedures reflect the direct-applicability model and the 17 August SESAM update date.
• Firms should consider documenting the timing of list ingestion, screening completion, disposition of alerts, any blocked or frozen assets, and any reports or licence requests submitted to SECO for audit and supervisory purposes.

What changed

The UN sanctions committee changed the list of sanctioned individuals, companies and organisations covered by SR 946.231.08. Switzerland applies the change directly, without a separate Swiss legislative or regulatory adoption step. SECO updated SESAM, the SECO Sanctions Management database described as authoritative for Switzerland, on 17 August 2026 and published the amendment on its website.

Key dates

2026-08-13

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida list; independent notices describe amendments to four entries.

2026-08-14

SECO updated the Swiss SESAM database and published the corresponding Swiss sanctions-list update.

2026-08-17

FINMA published its updated sanctions notice drawing attention to the directly applicable Swiss list change.

Suggested considerations

• Compliance teams may wish to obtain the amended UN list and the updated SESAM data, identify the three amended individuals and one amended entity, and map all aliases, dates of birth, nationalities, addresses, registration details and other identifiers into screening systems.
• Firms should consider immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, vendors, payment beneficiaries and relevant historical transactions against the amended data.
• Where a potential match is identified, firms should consider suspending the relevant transaction or relationship pending a documented false-positive assessment and escalating a confirmed or unresolved match to sanctions, legal and MLRO governance channels.
• For a confirmed match, firms should consider applying the asset-freeze restrictions under SR 946.231.08, preventing funds or economic resources from being made available directly or indirectly to or for the benefit of the designated person or entity, and assessing applicable Swiss notification and reporting requirements.
• Firms should retain evidence of the SESAM and screening-data update, screening timestamps, alert dispositions, approvals, transaction holds and any regulatory or law-enforcement communications.
• Control owners may wish to test whether outsourced screening providers, payment filters, correspondent-bank interfaces and crypto blockchain analytics received the update without delay.
• Compliance teams may wish to note the market reading reflected in parallel official-industry notices: the practical expectation is operational list maintenance and prompt rescreening, not merely awareness of the FINMA publication.

What changed

The list entries covered by the Ordinance of 2025-03-21 on Measures Against Persons and Organisations Connected with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) were amended; the available public notices indicate amendments to three individuals and one entity, rather than a new standalone FINMA rule. The amendments became directly applicable in Switzerland through the UN sanctions-list mechanism, and SECO incorporated them into SESAM on 2026-08-14.

Key dates

19 March 2026

- WBF amends Annex 8, removing 7 natural persons

20 March 2026, 23:00 UTC Deadline

- Changes enter into force; firms must adjust compliance systems accordingly

Suggested considerations

• Screen client databases and transaction records against the updated SESAM database to identify and release any asset freezes or restrictions on the 7 delisted persons, confirming no residual sanctions apply.
• Report any affected business relationships to SECO as per ordinance requirements; conduct additional due diligence under Art. 6 GwG if suspicions remain, and file SARs with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved.
• Update internal sanctions screening tools, policies, and staff training to reflect the SESAM changes; document all reviews for audit trails.
• Monitor FINMA's news and MyFINMA for further updates, as lists are continuously revised.

What changed

• - Amendment to Annex 8 of SR 946.231.176.72 by the Federal Department for Economic Affairs, Education and Research (WBF) on March 19, 2026, removing 7 natural persons from the sanctions list.
• Update to the official Swiss sanctions database SESAM (SECO Sanctions Management), published urgently on SECO's website.
• This delisting narrows the scope of asset freeze obligations under the ordinance, but core prohibitions on transactions, asset blocking, and reporting for remaining listed parties persist.

Key dates

12 December 2025

- Initial adoption of partial 19th package measures, adding 64 persons/organizations to Swiss sanctions list

13 December 2025

- Entry into force of December 2025 sanctions expansions (related prior update)

26 February 2026

- New measures from EU 19th sanctions package enter into force in Switzerland

Suggested considerations

• Implement all prohibitions immediately: Block crypto services to Russian nationals/companies; halt transactions with ruble-pegged stablecoins like A7A5; cease use of banned messaging services for payments.
• Screen and freeze assets of sanctioned persons/entities (~2,600 total); report affected business relationships to SECO.
• Conduct additional due diligence under Art. 6 GwG on suspicions; if unresolved, file immediate suspicious activity report to money laundering reporting office under Art. 9 GwG (SECO report does not exempt this).
• Update sanctions screening tools, client onboarding, and transaction monitoring for new crypto/trade restrictions; review exposures to energy/finance goods listed.

What changed

• - Crypto Restrictions: Complete ban on providing any crypto services to Russian nationals and companies; prohibition on transactions involving specific ruble-backed crypto assets, such as the...
• Payment Systems: Expansion of bans on using certain specialized messaging services for payment traffic.
• Trade/Goods Bans: Expanded list of goods contributing to Russia's military/technological strengthening, including metals for weapon systems, fuel production products, and acyclic hydrocarbons (key...
• Sanctions List Expansion: Builds on December 12, 2025 addition of 64 persons/organizations; Swiss list now aligns fully with EU's, covering ~2,600 targets subject to asset freezes related to Ukraine...
• Related EU 19th package details (adopted by Switzerland) include sanctions on Rosneft/Gazprom Neft, shadow fleet ships, new banks, payment systems like Mir/SPFS, and import bans on LNG/acyclic...

Key dates

Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00)

- Prior amendment effective dates, illustrating pattern of rapid implementation

January 13, 2026

- Publication of amendments by WBF, triggering immediate review obligations

November 22, 2026

- Current expiry of ordinance (subject to extension)

Suggested considerations

• Screen clients, transactions, and assets against updated sanctions lists for Russian/Ukrainian designations, focusing on asset freezing (no management/use except administrative actions) and economic resources (no sales, leasing, or financing).
• Block prohibited activities in energy sector, financial services (e.g., derivatives, crypto, guarantees), and related exports/financing; report any frozen assets to authorities.
• Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11).
• Monitor FINMA's sanctions page for full ordinance text and related guidance.

What changed

The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibitions on asset management or use except for normal administrative actions by financial institutions.