Investment Management in Switzerland

Key dates

10 August 2026

- The WBF amended Annexes 2 and 8 of the Ukraine sanctions ordinance and published the changes on its website

12 August 2026 Deadline

- The amended measures are published by FINMA and become operationally relevant for compliance teams

12 August 2026, 23:00

- The amended sanctions measures enter into force

Suggested considerations

• Firms must immediately screen customers, counterparties, and beneficial owners against the updated Annex 2 and Annex 8 listings and identify any matches.
• Firms must block and freeze any assets or economic resources belonging to sanctioned persons covered by the updated ordinance.
• Firms must report the affected business relationships to SECO in accordance with the ordinance.
• Firms must perform additional fact-finding under Article 6 GwG/AMLA whenever the sanctions hit or surrounding facts create suspicion that cannot be dismissed.
• Firms must submit an immediate suspicious activity report to MROS under Article 9 GwG/AMLA if the suspicion remains unresolved after additional clarifications.

What changed

• - The WBF amended Annex 2 and Annex 8 of the Swiss ordinance on measures connected with the situation in Ukraine, updating the sanctions list and/or restrictions applicable under SR 946.231.176.72.
• The amended measures become effective today at 23:00, meaning firms must be ready to apply the updated prohibitions without delay.
• Financial intermediaries must implement the prohibitions contained in the ordinance, which includes sanctions-related restrictions beyond ordinary asset freezes.
• Financial intermediaries must freeze the assets of sanctioned persons covered by the update.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

10 August 2026

- The WBF amended Annex 2 of the Sudan sanctions ordinance, according to the related Swiss official notice

11 August 2026

- The updated Sudan sanctions measures enter into force at **23:00**

Suggested considerations

• Firms must update sanctions screening systems immediately to reflect the amended Sudan Annex 2 list in SESAM.
• Firms must identify and freeze any assets or economic resources belonging to or controlled by newly listed persons.
• Firms must block prohibited transactions and services involving sanctioned Sudan-related persons or entities.
• Firms must review all existing customer, counterparty, and beneficial owner relationships for matches against the updated list.
• Firms must report affected business relationships to SECO in line with the ordinance.

What changed

• - The WBF amended Annex 2 of the ordinance of 25 May 2005 on measures against Sudan (SR 946.231.18).
• The Swiss authoritative sanctions database SESAM was adjusted to reflect the change.
• The changes take effect today at 23:00, making the update operationally urgent for Swiss financial intermediaries.
• Financial intermediaries must implement the prohibitions under the ordinance, including freezing assets of sanctioned persons.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

10 August 2026

- The WBF amended the list of sanctioned persons, companies, and organizations under the South Sudan measures

11 August 2026

- FINMA published the updated sanctions notice and stated that the urgent amendment would be published on the WBF website the same day

11 August 2026, 23:00

- The updated sanctions entry takes effect and becomes enforceable in Switzerland

Suggested considerations

• Re-screen customers, counterparties, beneficial owners, and payment flows against the updated SESAM sanctions data immediately.
• Freeze any assets or economic resources that match the updated South Sudan sanctions list as soon as the entry becomes effective.
• Block prohibited dealings and ensure no funds or economic resources are made available, directly or indirectly, to listed persons or entities.
• Report any affected business relationships to SECO without delay where a match is identified.
• Perform additional clarifications under Art. 6 GwG when sanctions hits or related suspicion indicators arise.

What changed

• - The WBF amended Annex 2 of the Swiss ordinance on measures against the Republic of South Sudan (SR 946.231.169.9), and FINMA relayed that the authoritative Swiss sanctions database SESAM has been...
• The urgent amendment takes effect today at 23:00, meaning firms must treat the revised list as enforceable from that time onward.
• Financial intermediaries must implement the prohibitions contained in the ordinance for the sanctioned parties.
• Financial intermediaries must freeze assets of sanctioned persons, companies, and organizations.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

16 July 2026

- The competent UN sanctions committee changed the list of sanctioned persons, companies, and organizations for the Democratic Republic of Congo

17 July 2026

- SECO updated the Swiss sanctions database SESAM and published the change for Switzerland

17 July 2026

- The updated sanctions lists became directly applicable in Switzerland without delay

Suggested considerations

• Review sanctions screening results immediately against the updated Congo-related list in SESAM and any internal watchlists to identify matching clients, counterparties, and beneficial owners.
• Freeze assets and block prohibited dealings involving newly designated persons, companies, or organizations as required by the ordinance.
• Report affected business relationships to SECO in line with the sanctions ordinance requirements.
• Perform enhanced internal clarifications under Article 6 GwG/AMLA whenever a sanctions hit or other red flags create suspicion.
• File an immediate suspicious activity report with the Money Laundering Reporting Office under Article 9 GwG/AMLA if doubts cannot be resolved.

What changed

• - The UN sanctions committee amended the list of sanctioned individuals, companies, and organizations relating to the Democratic Republic of Congo on 16 July 2026.
• The change is directly applicable in Switzerland, so firms cannot wait for a separate Swiss implementing act before acting on the updated list.
• SECO updated the Swiss sanctions database SESAM on 17 July 2026 and published the update on its website.
• Financial intermediaries must implement the prohibitions set out in the ordinance, including freezing the assets of sanctioned persons.
• Financial intermediaries must report the affected business relationships to SECO.

Key dates

08 June 2012

- Original Ordinance on Measures against Syria (SR 946.231.172.7) entered into force, establishing the sanctions framework and Annex 7

15 June 2026

- WBF amended the list of sanctioned persons, companies, and organisations in Annex 7 of the Syria sanctions ordinance and updated the Swiss SESAM sanctions database; SECO published the updated list on its website

16 June 2026 Deadline

- The amended measures, including changes to the Annex 7 Syria sanctions list, enter into force at 23:00, from which time financial intermediaries must fully apply the new listings and obligations

Suggested considerations

• Perform an immediate update of sanctions screening lists and tools to incorporate the revised Syria Annex 7 entries as reflected in the SESAM database.
• Identify all customers, beneficial owners, counterparties, and transactions that match or potentially match the updated Syria sanctions list, including retrospective screening where systems permit.
• Freeze without delay all assets and economic resources held or controlled by persons, entities, or organisations that are newly listed or affected by changes under the updated Annex 7.
• Block any new or pending transactions that would make funds or economic resources available, directly or indirectly, to persons and entities designated under the updated Syria list.
• Report all affected business relationships and frozen assets to SECO in accordance with the reporting requirements of the Syria sanctions ordinance and SECO guidance.

What changed

• - The WBF has amended Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7), changing the list of sanctioned persons, companies, and organisations connected to Syria.
• The Swiss sanctions database SESAM (SECO Sanctions Management) has been updated to reflect these changes, and SECO has published the amended list on its website.
• The updated measures, including asset-freeze and prohibition obligations, enter into force on 16 June 2026 at 23:00, making the revised Syria list immediately enforceable for Swiss-supervised...
• Financial intermediaries are explicitly required to implement the applicable prohibitions, including restrictions on making funds or economic resources available to listed persons, entities, and...
• Financial intermediaries must freeze the assets and economic resources of the persons, companies, and organisations newly listed, relisted, or otherwise affected by the Annex 7 amendment.

Key dates

04 March 2022

– Original Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) enters into force, establishing the framework for Annex 8 sanctions and related financial measures

15 June 2026

– WBF amends Annex 8 of the Ordinance and publishes the changes on its website, updating the list of sanctioned persons and entities

15 June 2026 Deadline

– The amended measures under Annex 8 enter into force at 23:00, from which time financial intermediaries must have implemented the new prohibitions, asset freezes, and reporting processes

Suggested considerations

• Review the updated Annex 8 of SR 946.231.176.72 as published by the WBF and obtain the latest Swiss sanctions-list data (including from SESAM/SECO where used) before the 23:00 effective time.
• Update internal sanctions screening lists, vendor‑provided screening tools and watchlist filters to incorporate all new and amended entries in Annex 8.
• Run an immediate batch screening of all customers, beneficial owners, controlling persons, counterparties, securities holdings and payment flows against the updated Annex 8 once the changes are operative.
• Identify all existing and pending business relationships that match updated Annex 8 entries and classify them as sanctioned in internal systems.
• Freeze without delay any assets, accounts, securities, or other economic resources belonging to, owned, held or controlled by persons and entities listed in Annex 8, in line with the Ordinance.

What changed

• - Annex 8 of the Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72) has been amended by the WBF to update the list of sanctioned persons and...
• The WBF has published the updated Annex 8 and associated sanctions-list changes on its website, making these changes the operative reference for Swiss sanctions screening and asset-freeze obligations.
• The amended measures enter into force on 15 June 2026 at 23:00, creating an immediate and time‑critical requirement for financial intermediaries to align their controls with the new Annex 8 content.
• Financial intermediaries are instructed to implement all prohibitions arising from the Ordinance, including any new or expanded restrictions connected to the updated Annex 8 listings.
• Financial intermediaries must freeze the assets of persons and entities newly designated or otherwise affected by the Annex 8 amendment and ensure no prohibited transactions or services are carried...

Key dates

17 October 2018

- Original Ordinance on Measures against Myanmar (SR 946.231.157.5) enters into force, establishing the sanctions framework and Annex 1

01 June 2026

- WBF amends the list of sanctioned persons, companies and organisations in Annex 1 of the Myanmar sanctions ordinance

02 June 2026

- SECO publishes the updated Myanmar sanctions list and SESAM data on its website

02 June 2026, 23:00

- The Myanmar sanctions list amendment enters into force and becomes binding for Swiss financial intermediaries

Suggested considerations

• Immediately screen all customers, beneficial owners, counterparties, and related parties against the updated Myanmar Annex 1 list using the current SESAM sanctions data as of the 23:00 effective time.
• Freeze without delay any assets, accounts, or other economic resources held or controlled by persons, entities, or organisations newly listed under the Myanmar sanctions ordinance.
• Block any new or existing transactions that would breach the prohibitions of the Myanmar sanctions ordinance in light of the updated Annex 1 list.
• Submit timely reports to SECO on all business relationships and frozen assets related to persons and entities listed in the updated Myanmar sanctions list, in line with the reporting provisions of the ordinance.
• Conduct additional due diligence and clarifications under Article 6 GwG where there are indications or suspicions of money laundering, terrorism financing, or sanctions breaches in connection with Myanmar-related relationships.

What changed

• - Annex 1 of the Ordinance of 17 October 2018 on Measures against Myanmar (SR 946.231.157.5) has been amended by the WBF, changing the list of sanctioned persons, companies and organisations.
• The SECO sanctions database SESAM (SECO Sanctions Management) has been updated to reflect the amended Myanmar sanctions list.
• The amendment to the Myanmar sanctions list and corresponding SESAM data becomes legally effective at 23:00 on the date indicated in the FINMA notice.
• Financial intermediaries are required to implement the prohibitions set out in the Myanmar sanctions ordinance with respect to the updated list, including blocking the assets of all listed persons,...
• Financial intermediaries must report business relationships affected by the Myanmar sanctions list changes to SECO in line with the sanctions ordinance.

Key dates

13 April 2026

- WBF publishes changes to Annexes 12 and 14 and updates SESAM database.

14 April 2026, 23:00 UTC

- Changes enter into force; asset freezes and prohibitions become mandatory.

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database and Annexes 12/14 immediately.
• Freeze assets of any newly sanctioned or amended persons/entities without delay.
• Report all affected business relationships to SECO promptly.
• Conduct enhanced due diligence under GwG Art. 6 for any suspicion; if unresolved, file a suspicious activity report (SAR) with MROS under GwG Art. 9.
• Monitor FINMA's MyFINMA portal and website for ongoing updates; update internal sanctions screening systems.[User Query]

What changed

• - Amendments to Annexes 12 and 14 of the Ordinance SR 946.231.143.6, updating the list of sanctioned persons, companies, and organizations in the context of Iran sanctions.[User Query]
• Updates propagated to the SESAM database, published on the WBF/SECO website.[User Query]
• Standard requirements reiterated: Implement prohibitions, freeze assets of sanctioned parties, and report affected business relationships to SECO; SECO reporting does not exempt additional GwG Art.

Key dates

February 24, 2026

- UN Sanctions Committee amends Sudan list

February 25, 2026

- SECO updates SESAM database and publishes on its website; changes directly applicable in Switzerland

Immediate (upon publication) Deadline

- Financial intermediaries must freeze assets and report to SECO; no fixed deadline specified, but "unverzüglich" (without delay) for GwG AML reporting if suspicions persist

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM Sudan list via SECO's website or MyFINMA notifications.
• Freeze (block) assets of any matches and implement transaction prohibitions per the ordinance.
• Report affected business relationships to SECO promptly.
• Conduct additional due diligence under Art. 6 GwG for suspicions; if unresolved, file immediate suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG.
• Monitor FINMA's sanctions page for ongoing updates: https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/.

What changed

• - The UN Sanctions Committee for Sudan amended its list of sanctioned natural persons, companies, and organizations on February 24, 2026.
• SECO updated the SESAM (SECO Sanctions Management) database and published the changes on its website on February 25, 2026.
• This triggers direct applicability in Switzerland under the Federal Council's 2016 ordinance for automatic adoption of UN sanctions lists, amending Annex of SR 946.231.18 (Ordinance on Measures...
• Financial intermediaries are required to implement prohibitions, freeze assets, and report affected business relationships to SECO; SECO reporting does not exempt AML suspicions under Art.

Key dates

5 February 2026

- UK adds six individuals to Sudan sanctions list (e.g., SUD0026 to SUD0031), informing Swiss alignment

18 February 2026

- Switzerland publicly notes addition of seven individuals to Sudan list via ACAMS report

19 February 2026 Deadline

- WBF amends Annex 2 of SR 946.231.18, effective immediately for compliance (publication date)

12 March 2026 Deadline

- UN Panel of Experts interim report due on Sudan sanctions implementation

12 October 2026

- UNSC Sudan sanctions regime extension expires unless renewed

Suggested considerations

• Immediate screening: Review client databases, transactions, and assets against updated Annex 2 for the seven new designations; freeze any matching funds or resources without delay.
• Reporting: Notify FINMA or relevant authorities (e.g., State Secretariat for Economic Affairs SECO) of any holdings or suspicions; relevant firms must report to OFSI equivalents in Switzerland.
• No dealings: Cease all transactions, payments, or benefits to/from designated persons unless licensed; maintain records for 10+ years per Embargo Act.
• Controls update: Enhance sanctions screening tools, train staff, and audit AML/sanctions programs for Sudan-specific risks like RSF financing or mercenaries.
• Licensing check: Apply for exceptions via SECO if needed for humanitarian or existing obligations.

What changed

• - Amendment to Annex 2 of SR 946.231.18 by WBF, adding seven individuals to the Sudan sanctions list, mirroring recent UN-aligned updates (e.g., UK additions on 5 February 2026 for persons like...
• Sanctions include asset freezes, prohibitions on dealings with designated persons' funds or economic resources, and mandatory reporting to authorities, consistent with Switzerland's implementation of...
• Updates reflect global coordination, with UNSC Resolution 2791 (2025) extending the Sudan regime to 12 October 2026, emphasizing targeted measures against human rights violations, humanitarian...

Key dates

January 12, 2026

- WBF publishes amendment to Annex 2

January 13, 2026, 23:00 UTC Deadline

- Changes enter into force; immediate implementation required

December 12, 2026

- Related EU sanctions extended to this date (Swiss alignment expected)

Suggested considerations

• Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness.
• Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available.
• Report affected business relationships to SECO without delay.
• Conduct GwG Art. 6 due diligence on suspicions; file Art. 9 reports to the Money Laundering Reporting Office if unresolved.
• Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools.

What changed

• - Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions.
• Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website.
• Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art.

Key dates

January 5, 2026

- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons

January 13, 2026

- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)

Immediate Deadline

- Compliance obligations commence upon publication; no grace period for implementation

Suggested considerations

• *Immediate Screening: Conduct comprehensive screening of all client and counterparty databases against the updated Annex 1 designations within 24-48 hours of publication.
• *Asset Identification: Identify and document any assets, accounts, or positions held by or on behalf of newly designated persons/entities.
• *Freeze Implementation: Immediately freeze all identified assets and block all transactions involving designated parties.
• *Notification: Report any blocked assets to SECO as required under Swiss sanctions legislation (typically within 10 business days).
• *Transaction Review: Suspend all pending transactions with Venezuela-related counterparties pending compliance verification.

What changed

• The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela.
• Update their sanctions screening systems with revised designations
• Identify any existing relationships with newly designated or de-designated persons/entities
• Implement immediate asset freezing for any newly added designations
• Cease all transactions with blocked parties unless specifically authorized

Key dates

5 January 2026, 11 a.m. Deadline

Ordinance enters into force; immediate asset freezing and reporting required

4 January 2030

Asset freeze expires after four years, unless extended or revoked

Suggested considerations

• Screen and identify: Immediately review client lists, accounts, and transactions against the ordinance annex listing 37 persons; use FINMA's ordinance publication and Classified Compilation of Federal Law.
• Freeze assets: Block all assets (funds, securities, real estate, etc.) of listed persons; prevent any transfers, payments, or dealings.
• Report to MROS: Notify MROS of frozen assets or relevant knowledge without delay, following FIAA protocols; include details on asset nature, value, and location.
• Internal updates: Update compliance systems, screening tools, and PEP/ sanctions databases; train staff on FIAA obligations.
• Document compliance: Maintain records of screening, freezes, and reports for potential FINMA audits; monitor for updates via FINMA and Federal Council releases.

What changed

• - Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously...
• Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA...
• Duration: The freeze is valid for four years until 4 January 2030, unless revoked earlier.
• Legal basis: Enacted under Article 3 FIAA as a "freeze for mutual legal assistance" post-political change, distinct from but additive to 2018 Venezuela sanctions under the Embargo Act.
• Penalties: Non-compliance with freezing may result in up to three years' custody; reporting violations up to CHF 250,000 fine.

Key dates

29 October 2025

- Prior expansion decision (related 18th EU package adoption)

30 October 2025

- Entry into force of October measures (export restrictions, RDIF transaction bans)

13 December 2025 Deadline

- Measures enter into force; immediate implementation required

31 December 2025

- Extension of certain derogations (e.g., Russia investment withdrawals)

Suggested considerations

• Immediate screening: Review client lists, transactions, and assets against updated SECO sanctions lists (published by WBF) for matches to 22 persons, 42 entities, 116 vessels, 45 export-controlled firms, 5+4 banks, and 8 third-country firms.
• Asset freezing: Block and freeze any matching assets/funds; prohibit making available.
• Transaction halts: Cease dealings with listed banks, entities, vessels, or sanctioned goods/services.
• Reporting: Notify SECO of frozen assets, blocked transactions, or existing business relationships immediately; conduct additional due diligence on suspicions per Art. (FINMA guidelines).
• Ongoing monitoring: Update compliance systems for dynamic lists; train staff on shadow fleet risks and third-country evasion.

What changed

• - Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
• Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
• Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
• Financial transaction bans: Five Russian banks and four branches of Russian banks in third countries banned from transactions, especially those using Russian payment systems; eight third-country...

Key dates

Immediate (as of December 10, 2025) Deadline

- Financial intermediaries must block assets and report to SECO without delay, per automatic application of UN sanctions

December 9, 2025

- UN Sanctions Committee decision amending the Iraq sanctions list

December 10, 2025

- SECO publishes update on its website and updates SESAM database; changes enter into force immediately in Switzerland

Suggested considerations

• Screen against SESAM database: Immediately rescreen client portfolios, transactions, and business relationships against the updated Iraq sanctions list via SECO's SESAM tool (https://www.seco.admin.ch/sesam).
• Asset freeze: Block and freeze any assets, funds, or economic resources belonging to newly sanctioned parties; do not dispose of or make available.
• Report to SECO: Notify SECO of any matches or business relationships via the designated reporting channel within required timelines (typically immediate for freezes).
• Internal review: Update compliance systems, screening tools, and policies; conduct targeted audits for Iraq/Middle East exposure; train staff on implementation.
• Document compliance: Maintain records of screening, freezes, and reports for FINMA audits.

What changed

• - The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and...
• Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
• Financial intermediaries must implement prohibitions, freeze assets of newly listed or adjusted entities, and notify SECO of any impacted business relationships, consistent with prior Iraq sanctions...

Key dates

18 October 2024

- UN Security Council Resolution 2752 adopted, expanding arms embargo (basis for Swiss/UK updates)

20 March 2025

- Canadian amendments add 3 individuals (related context)

Immediate (publication date: 21 October 2025) Deadline

- Swiss firms must check accounts, freeze assets or economic resources of newly listed persons without prior notice, and report to SECO/FINMA without delay

23 July 2025

- UK Haiti Sanctions Amendment Regulations enter force, reflecting similar UN changes

17

20 October 2025; - UNSC renews regime for one year, adds 2 entries to sanctions list (UK/Jersey notices align with Swiss publication)

Suggested considerations

• Screening and Freezing: Immediately review client databases, accounts, and holdings against the updated SECO Haiti sanctions list; freeze funds/economic resources of designated persons/entities without notice or delay; do not deal with or make available such assets indirectly.
• Reporting: Notify SECO (via [email protected] or portal) and FINMA of matches, providing details on frozen assets; report any additional compliance-facilitating information.
• Ongoing Monitoring: Update transaction screening systems for expanded arms embargo prohibitions (e.g., no financial services for military goods/technology to Haiti-connected persons); cease brokering or technical assistance if applicable.
• Licensing Checks: Refrain from activities unless licensed by competent authorities (e.g., SECO for exemptions).
• Documentation: Maintain records of checks and actions for audits; train staff on updated definitions (e.g., "military goods," "connected with Haiti").

What changed

• - Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals,...
• Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial...
• Switzerland implements via SECO's sanction ordinances, with FINMA enforcing for supervised entities; parallels international updates like UN Resolution 2752 (2024) and 2794 (2025), which reintroduce...

Key dates

20 October 2025

- Amendment to the annex published by WBF/EAER

21 October 2025

- FINMA publishes updated sanctions notice and notifies via MyFINMA

21 October 2025, 11:00 pm

- Measures enter into force; immediate blocking and screening obligations apply

Suggested considerations

• Block and report: Freeze any newly or modifiedly sanctioned assets; report to FINMA/SECO via MyFINMA if matches found.
• Update compliance systems: Integrate the annex changes into screening tools, policies, and training; conduct risk assessments for Nicaragua exposure.
• Monitor ongoing: Subscribe to FINMA news (https://www.finma.ch/en/news/) and SECO updates for further deltas.
• Document implementation to demonstrate due diligence in case of FINMA audits.

What changed

• - Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction...
• These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from...
• No broader structural changes to the ordinance itself; this is a targeted annex update, similar to frequent "delta" amendments published by SECO.

Key dates

21 October 2025, 23:00 Uhr

- Changes enter into force, binding on all Swiss financial intermediaries

29 September 2025

- Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/

20 October 2025

- WBF amends SESAM database and publishes urgent update on its website

12 December 2025

- Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/

Suggested considerations

• Immediate screening: Run full client and transaction screening against updated SESAM list via SECO's website or integrated tools.
• Asset freeze: Block any funds, assets, or economic resources of newly listed parties without delay; report freezes to SECO within specified timelines (typically 30 days).
• Transaction blocks and reporting: Halt prohibited dealings; file suspicious activity reports (SARs) to Money Laundering Reporting Office Switzerland (MROS) if Iran exposure suspected.
• Due diligence enhancement: Review existing Iran-related exposures, especially shadow banking, oil/petroleum networks, or IRGC-linked entities; update risk assessments.
• Internal controls: Ensure automated screening tools are synced with SESAM by effective date; train staff on updates.

What changed

The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication and binding effect under existing ordinances.

Key dates

October 9, 2025

- FINMA Guidance 04/2025 published and takes effect immediately

January 1, 2029

- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted

Suggested considerations

• *Acknowledge the extended timeline: Update internal compliance calendars and risk management frameworks to reflect the January 1, 2029 deadline rather than January 1, 2026.
• *Monitor FinMIA revision: Track ongoing legislative developments regarding the permanent regulatory framework for OTC derivatives to prepare for post-2029 compliance requirements.
• *Assess competitive positioning: Evaluate whether the extended transitional period affects trading strategies, counterparty relationships, or market competitiveness relative to EU and UK peers.

What changed

• The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
• Previous deadline: January 1, 2026
• New deadline: January 1, 2029
• Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or...
• Regulatory basis: FINMA Guidance 04/2025, issued October 9, 2025, under authority granted by Article 131 paragraph 6 FinMIO The extension does not eliminate the collateral exchange obligation;...

Key dates

8 October 2025, 23:00 hours

- Changes enter into force; asset freezes and prohibitions apply immediately thereafter

6 October 2025

- DEFR modifies the sanctions list and updates SESAM database

Suggested considerations

• Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00).
• Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system.
• Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure.
• Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits.

What changed

• - Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance.
• Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance.
• No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations.

Key dates

October 8, 2025, 23:00 Uhr Deadline

- Changes enter into force; immediate implementation required for asset freezes and prohibitions

October 6, 2025

- WBF adjusts SESAM database and publishes changes on its website

October 7, 2025

- FINMA publishes the sanctions notice

Suggested considerations

• Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art. 6.
• Freeze assets of any matched listed persons/entities and prohibit new business.
• Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain.
• Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications.
• Document compliance actions to demonstrate adherence in audits or FINMA inquiries.

What changed

• - Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025.
• Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g.,...
• Prohibition on dealings with listed persons/entities; mandatory asset freeze and reporting obligations under the ordinance and Geldwäschereigesetz (GwG).

Key dates

October 8, 2025 at 23:00

- Changes enter into force; asset freezes and prohibitions apply immediately

October 6, 2025

- WBF publishes update to Annex 7 and SESAM database

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness.
• Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions.
• Report all impacted business relationships to SECO promptly.
• Conduct GwG due diligence (Art. 6) on any suspicions; file with Money Laundering Reporting Office (Art. 9 GwG) if unresolved.
• Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits.

What changed

• - The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management).
• Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO.
• Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art.

Key dates

August 18, 2025

- WBF published updated sanctions notification for Iran (Annex 7 modifications)

August 28, 2025

- Germany, France, and UK triggered UN snapback mechanism

September 15, 2025

- Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)

September 27, 2025

- UN nuclear-related sanctions against Iran automatically reinstated

September 28, 2025

- EU reactivated suspended sanctions related to Iran's proliferation activities

Suggested considerations

• *Immediate compliance obligations:
• *Sanctions List Screening: Update all sanctions screening systems and databases to reflect the August 2025 Annex 7 modifications and subsequent December 2025 total revision
• *Transaction Review: Conduct comprehensive review of existing Iranian counterparties, customers, and beneficiaries against updated FINMA-published lists
• *Account Monitoring: Identify and freeze accounts or assets belonging to designated persons and entities; report frozen assets to authorities
• *Reporting: File mandatory notifications with FINMA and relevant authorities regarding any identified matches or transactions with sanctioned parties

What changed

The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG). The broader context shows that Switzerland was preparing for significant sanctions escalation: on December 12, 2025, the Swiss Federal Council conducted a total...

Key dates

18.08.2025

- SECO publishes amendment to Annex 2

19.08.2025

- FINMA issues public notification of the update

20.08.2025

- Amendment enters into force; asset freezes and prohibitions apply immediately

Suggested considerations

• Screen client portfolios, transactions, and relationships against the updated SESAM database and Annex 2 via FINMA's website or MyFINMA portal.
• Freeze assets of newly listed parties without delay; block prohibited transactions.
• Report affected business relationships to SECO promptly; conduct additional GwG Art. 6 due diligence if suspicions arise, and file SARs with the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
• Update internal sanctions screening systems and train staff; document compliance for audit trails.

What changed

• - SECO amended Annex 2 of the Ordinance, likely adding, removing, or modifying listings of sanctioned persons, companies, or organizations related to South Sudan.
• The update requires implementation of prohibitions (e.g., no new business), asset freezing for listed parties, and reporting of affected relationships to SECO.
• Changes stem from ongoing enforcement of UN and EU sanctions, with Switzerland implementing via the Embargo Act; Annexes are dynamically updated.

Suggested considerations

• Screen against updated SESAM database: Immediately query SECO's Sanctions Management system and Annex 2 for new/updated designations; freeze any matching assets and report to SECO/FINMA as required.
• Transaction screening and blocking: Halt any funds transfers, services, or economic resources to/from designated parties; document due diligence.
• Internal compliance update: Review client portfolios, KYC files, and transaction monitoring systems for Sudan exposure; train staff and update policies.
• Reporting obligations: Notify FINMA/SECO of any frozen assets or potential breaches within regulatory timelines (typically 30 days for suspicious activity under AMLA).
• Audit and evidence retention: Maintain records of screening/compliance actions for FINMA inspections.

What changed

• - Amendment to Annex 2 of SR 946.231.18, which lists designated persons, entities, and assets subject to sanctions such as asset freezes and prohibitions on making funds or economic resources...
• Updates reflected in the official Swiss sanctions database SESAM (SECO Sanctions Management), published on the SECO website, ensuring harmonized implementation across Switzerland.
• Urgent (dringliche) amendment entering into force immediately, bypassing standard consultation periods to address time-sensitive developments in the Sudan conflict. Specific details of added/removed...

Key dates

August 5, 2025

- UN Sanctions Committee decision modifying the Iraq sanctions list

August 13, 2025

- SECO published the updated sanctions notification and SESAM database modifications

Immediate

- Effective date in Switzerland (automatic application upon UN modification)

Suggested considerations

• *Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
• *Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
• *Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
• *Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
• *Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements

What changed

The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Council sanctions lists enter into force in Switzerland without delay.

Key dates

15 September 2025

- Harmonization of financial sanctions across multiple regimes (including Belarus) enters into force, clarifying fund crediting on blocked accounts and reporting

30 October 2025

- New provisions from Bundesrat decision on 29 October 2025 enter into force, requiring immediate implementation of updated Belarus measures

12 December 2025

- Publication of list expansions by WBF/SECO

13 December 2025

- Expansions to sanctions lists for Russia/Belarus (including 22 persons, 42 entities, 116 ships, 45 trade firms, 5 banks) take effect

Suggested considerations

• Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e.g., Annexes 3, 11a, 19) for freezes and prohibitions; block and report frozen assets/business relationships to SECO immediately.
• Conduct GwG Art. 6 due diligence on suspicions; if unresolved, file AML reports under Art. 9 GwG (SECO reporting does not exempt this).
• Cease prohibited activities: no loans, insurance, deposits >CHF 100k from Belarusians, specialized messaging for payments, or dealings with National Bank of Belarus.
• Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates.
• For trade/energy firms: Halt exports/imports of listed goods (e.g., oil, potash, machinery) and verify third-country counterparties.

What changed

The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19).

Key dates

28.06.2023

Original Ordinance effective date; (context for baseline measures)

11.08.2025

Publication of Annex update by WBF

12.08.2025

Measures enter into force; (based on similar recent updates; immediate effect standard)

Immediate (unverzüglich)

Report frozen assets to SECO

Suggested considerations

• Screen Client Base: Immediately rescreen all existing and prospective clients, relationships, and transactions against the updated SECO/FINMA Moldova sanctions list via MyFINMA portal.
• Freeze and Report Assets: Block all funds/economic resources of newly listed parties without delay; report details (e.g., account info, asset values) to SECO promptly.
• AML Due Diligence: Conduct enhanced checks under Art. 6 GwG; if suspicions persist post-SECO report, file suspicious activity report (SAR) with MROS under Art. 9 GwG.
• Internal Controls: Update screening tools, train staff, and document compliance to mitigate enforcement risk from FINMA.
• Monitor Ongoing: Subscribe to FINMA MyFINMA alerts and SECO updates for further Annex changes.

What changed

• - Updated Sanctions List: The WBF amended the Annex to include additional natural or legal persons, organizations, or entities subject to financial sanctions, effective immediately upon publication.
• Financial Sanctions Reinforced: Mandatory asset freezes (sperre von Vermögenswerten), prohibitions on making funds or economic resources available (Bereitstellungsverbote), and reporting requirements...
• No Change to Core Ordinance: The underlying Ordinance from June 28, 2023, is unchanged, but the Annex expansion triggers re-screening of existing relationships.

Key dates

March 7, 2025, 6:00 PM UTC

– Original Syria Asset Freezing Ordinance entered into force

July 31, 2025, 6:00 PM UTC

– Amendment to annex (list of designated persons) entered into force

Ongoing

– Immediate freezing obligation upon designation; no grace period applies

Four

year validity; – The ordinance remains valid for four years from March 7, 2025, unless extended or modified

Suggested considerations

• *Immediate compliance steps for financial institutions:
• *Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
• *Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
• *File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
• *Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities

What changed

The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices. The amendment operates under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA; SR 196.1), which provides the legal...

Key dates

October 17/20, 2025

UNSC Committee adds 2 entries to Sanctions List; Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response

October 18, 2024

UNSC Resolution 2752 adoption; Expands arms embargo scope, basis for national implementations

Immediate/publication date (2025/07/09 per FINMA notice)

Swiss Annex amendment effective; No grace period specified; aligns with "without delay" freezing requirements

July 23, 2025

UK Haiti Sanctions Amendment effective; Parallel indicator of timeline for UN-aligned changes

October 21, 2025

Swiss WBF/VTG announcement; Confirms amended sanctioned list

Suggested considerations

• Screen Immediately: Check client databases, accounts, and transactions against the updated SECO/UN Haiti Sanctions List for new designations; freeze assets/economic resources without prior notice.
• Cease Prohibited Activities: Halt dealings (direct/indirect) with designated parties, including financial services, brokering, technical assistance, or transfers related to military goods/technology.
• Report Findings: Notify SECO/FINMA of matches or frozen assets, providing additional compliance details; maintain records for audits.
• Update Policies/Systems: Revise sanctions screening tools, train staff, and monitor for "connected persons" under updated definitions.
• License Checks: Apply for exemptions only if explicitly available (e.g., humanitarian); no dealings without approval.

What changed

• - Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in...
• Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing travel bans, asset freezes, and arms...
• Swiss Implementation: FINMA oversees enforcement via SECO's sanction ordinances; updates require alignment with UN lists for asset freezing and prohibitions on dealings with designated parties.