General in Switzerland

Key dates

2026-11-02

WBF amended Annex 2 of the Ordinance of 25 May 2005 on Measures against Sudan (SR 946.231.18), modifying three individual entries.

2026-11-03 Deadline

The amended Sudan sanctions measures enter into force at 23:00 Swiss time; affected financial intermediaries must apply the relevant prohibitions, freeze assets and report affected relationships and blocked assets as required by the ordinance.

Suggested considerations

• Compliance teams should consider updating sanctions-screening data, including aliases and identifying information, from SESAM and the amended Annex 2 before the 23:00 effective time on 3 November 2026.
• Firms should consider screening customers, beneficial owners, counterparties, payment beneficiaries, securities positions and existing business relationships against all three modified entries, including historical and transliterated names where relevant.
• Where a potential match is identified, firms should consider applying the Article 2 financial-sanctions restrictions, preventing further availability of assets or economic resources, preserving relevant records and escalating the case for false-positive resolution and sanctions governance review.
• Firms should consider notifying SECO of affected business relationships and blocked assets in accordance with SR 946.231.18 and maintaining evidence of the decision, controls applied and notification submitted.
• Compliance teams may wish to assess whether a sanctions hit or related transaction creates additional money-laundering concerns requiring enhanced inquiries under Article 6 GwG and, if suspicions cannot be dispelled, an immediate Article 9 GwG report to the Money Laundering Reporting Office.
• Firms with cross-border operations should consider separately assessing whether the modified persons are also subject to EU, UK, US or other sanctions regimes, because the Swiss listing and any foreign restrictions may differ in scope and ownership or control consequences.
• Firms should consider validating batch-screening, real-time payment-screening, case-management and alert-escalation controls after the SESAM update, given the short notice between publication and effectiveness.

What changed

Three individual entries in Annex 2 were modified; the update is implemented through the Swiss SESAM sanctions database. The amended listings are subject to the financial sanctions in Article 2 paragraph 1 of SR 946.231.18, including the freezing of assets and economic resources and the prohibition on directly or indirectly making assets or economic resources available to listed persons. The relevant travel-ban provisions under Article 4 paragraph 1 also apply. Financial intermediaries must report affected business relationships and blocked assets to SECO.

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

2026-08-17

EAER amended Annexes 12, 13 and 14 and SECO updated the SESAM sanctions database.

2026-08-18 Deadline

The amendment became legally effective at 23:00 Swiss time; affected prohibitions, asset freezes and SECO reporting obligations applied from that time.

Suggested considerations

• Compliance teams may wish to obtain the effective 2026-08-18 23:00 SESAM dataset and run an immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, payment beneficiaries, securities positions and relevant transaction history.
• Firms should consider applying the Article 16 asset-freeze and availability prohibitions to positive matches, including assets or economic resources controlled indirectly, and escalating potential matches for ownership-and-control analysis rather than relying only on exact-name screening.
• Financial intermediaries should consider reporting affected business relationships and frozen assets to SECO without delay in accordance with the ordinance, while documenting the screening timestamp, match disposition, freeze decision and notification trail.
• Teams may wish to review pending and recurring Iran-related payments against Article 21, including the CHF 10,000 SECO reporting threshold, the five-working-day reporting period, and the CHF 50,000 prior-authorisation threshold.
• A SECO sanctions report should not be treated as a substitute for AMLA analysis: where circumstances create suspicion, firms should consider additional clarifications under Article 6 AMLA/GwG and an immediate MROS report under Article 9 AMLA/GwG if the suspicion cannot be dispelled.
• Firms should consider reviewing delisted and amended entries separately, because removal from an Iran annex does not necessarily resolve exposure under other Swiss, UN or foreign sanctions regimes or eliminate unrelated AML, proliferation-financing or reputational-risk concerns.
• Compliance and operations teams may wish to confirm that screening vendors, payment filters, case-management workflows, correspondent-bank controls and sanctions procedures recognise the 23:00 Swiss-time effective moment and preserve an auditable change-management record.

What changed

The amendment updates the Swiss SESAM sanctions database and the designation annexes of the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran. Six individuals were delisted, one entity record was amended, and two individuals and one entity were newly listed; the publication does not identify the parties in the FINMA notice itself, so firms should rely on the current SECO SESAM data rather than the notice's entry counts alone.

Key dates

2026-08-14

EAER amended Annexes 2 and 14a of the Ukraine Ordinance; one entity was removed from Annex 14a and 610 Annex 2 individual and entity entries were amended.

2026-08-17 Deadline

The amendments and resulting prohibitions, asset-freezing requirements and reporting implications take effect at 23:00 Swiss time; firms should have implemented screening and control changes by this time.

Suggested considerations

• Compliance teams should load the amended Annex 2 and Annex 14a data into sanctions-screening systems and complete identifier, alias, ownership and account-linkage checks before the 17 August 2026 23:00 effective time.
• Firms should compare the pre-amendment and post-amendment lists to distinguish the Annex 14a deletion from the 610 amended Annex 2 entries and should avoid treating an amended record as cleared without validating the current consolidated list.
• Firms should review customers, beneficial owners, counterparties, payment instructions, securities positions, custody assets and correspondent relationships against the amended records, including possible indirect ownership or control links.
• Where a match is confirmed, firms should consider stopping prohibited activity, freezing relevant funds and economic resources, restricting access in accordance with the Ordinance, and reporting the affected business relationship to SECO using the applicable reporting channel and form.
• For suspected sanctions evasion, inconsistent customer information or other money-laundering indicators, compliance teams may wish to document the Article 6 AMLA enhanced clarification and assess whether an immediate Article 9 AMLA report to the Money Laundering Reporting Office is required.
• Firms should document screening-rule changes, alert disposition, freeze decisions, SECO notifications, AMLA escalation decisions and any controlled release following the Annex 14a removal. Any unblocking should be preceded by checks for separate Annex 2 designation, ownership or other sanctions grounds.

What changed

The EAER amended Annex 2 and Annex 14a of SR 946.231.176.72. The official government notice indicates that one entity was removed from Annex 14a and the entries concerning 610 individuals and entities were amended in Annex 2; the publication does not state that all 610 entries are new designations, so firms should obtain and compare the underlying consolidated and delta lists before determining the precise status of each relationship. Financial intermediaries must implement the applicable prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO.

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.