FINMA Updates 2025

Key dates

September 28, 2025

- UN Security Council resolutions automatically reinstated (snapback mechanism triggered)

September 29, 2025

- EU reactivated suspended sanctions on Iran's proliferation activities

October 20, 2025

- Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings

October 21, 2025

- Updated sanctions list effective (23:00 UTC)

December 12, 2025

- Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)

Suggested considerations

• *Immediate (Completed by December 12, 2025):
• related transactions and accounts for compliance with expanded prohibitions
• *Short-term (By January 1, 2026):
• September 30, 2025 contracts under legacy exemption provisions
• related transactions

What changed

• The total revision introduces several critical regulatory shifts: Scope Expansion: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803,...
• Sale or supply of key energy sector equipment
• Gold, precious metals, and diamonds transactions
• Specific maritime equipment
• Designated software exports

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

December 9, 2025, 23:00 UTC

- Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date

Immediate Deadline

- Financial intermediaries required to implement changes according to SR 946.231.18 regulations

Suggested considerations

• *Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
• *System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
• *Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
• *Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
• *Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.

What changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan.

Key dates

18 July 2025

- EU adopts 18th sanctions package against Russia and additional Belarus measures

29 October 2025

- Swiss Federal Council decides to align and amends SR 946.231.116.9

30 October 2025

- New provisions enter into force

13 December 2025

- Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context

Suggested considerations

• Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists).
• Freeze assets of newly sanctioned persons/entities and prohibit dealings (e.g., no transactions with listed banks, no exports of restricted goods).
• Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist.
• Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e.g., SWIFT-like messaging for listed banks).
• Review third-party exposures (e.g., Drittländer firms) for evasion risks and document compliance efforts for FINMA audits.

What changed

• - Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
• Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening),...
• Requirements for financial intermediaries to implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
• Reporting to SECO does not exempt intermediaries from AML due diligence under Art. 6 GwG (Anti-Money Laundering Act) or suspicious activity reports under Art.

Key dates

October 29, 2025

- Federal Council decision adopted

October 30, 2025

- Measures effective date

Ongoing Deadline

- Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs)

Suggested considerations

• *Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
• *Freeze assets of all sanctioned persons and entities immediately upon notice
• *Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
• *Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
• *Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy

What changed

• Financial Sector Restrictions The Bundesrat expanded transaction prohibitions on Russian banks substantially:
• Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
• Introduced new transaction prohibitions for 22 additional Russian banks
• Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previously limited to RDIF-financed projects Export...
• Chemical components for fuel production

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.

Suggested considerations

• Screen and freeze assets: Immediately identify and block assets of newly sanctioned persons/entities per updated annexes; do not release without authorization.
• Report to SECO: Notify SECO of all affected business relationships without delay.
• Conduct AML due diligence: Perform additional clarifications under Art. 6 GwG (Anti-Money Laundering Act) on suspicions; file suspicious activity reports (SARs) with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved—SECO reporting does not substitute this.
• Review transactions: Halt prohibited activities (e.g., payments to/from listed banks, exports of controlled goods, RDIF investments); update screening tools and client onboarding processes.
• Document compliance: Maintain records of screenings, blocks, and reports for FINMA audits.

What changed

• - Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement.
• Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
• These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additional Russian banks, and prohibitions on...

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

Immediate upon publication (19 August 2025) Deadline

- Swiss firms must implement updated sanctions list screening and freeze applicable assets/transactions per FINMA/SECO requirements (https://www.finma.ch/en/news/2025/08/20250819-sr-946-231-149-82/)

1 May 2026

- Expiration of UN authorizations/measures on illicit petroleum exports from Libya (Resolution 2769)

15 May 2026

- End of UN Panel of Experts mandate monitoring Libya sanctions

Suggested considerations

• Screen immediately: Run full client, transaction, and asset portfolios against the updated SECO list (SR 946.231.149.82) for matches on newly added/removed designations.
• Freeze assets: Identify and freeze any funds/economic resources of designated parties without delay; report to SECO/FINMA.
• Cease dealings: Halt direct/indirect provision of funds, financial services, or trade facilitation to/from listed parties.
• Update systems: Refresh sanctions screening tools, policies, and training; document compliance evidence.
• Monitor related flows: Heighten scrutiny on Libyan petroleum trade, LIA assets, and arms-related exemptions per UN Resolution 2769.

What changed

The core change is an amendment to the list of sanctioned natural persons, companies, and organizations in SR 946.231.149.82, as published by SECO. This reflects broader UN Security Council updates via Resolution 2769 (2025), which introduced new designation criteria for individuals/entities supporting armed groups or criminal networks through illicit exploitation/export of crude oil or refined petroleum from Libya, alongside exemptions for certain arms embargo activities, allowances for Libyan Investment Authority (LIA) frozen cash investments in low-risk deposits, and extensions of related...

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

Immediate upon publication (August 13, 2025)

- Swiss sanctions lists updated; asset freezes and prohibitions take effect instantly for newly designated parties

15 December 2025

- Noted FINMA reference for ongoing list updates and independent freezing measures

31 July 2026

- EU sectoral sanctions against Russia renewed until this date (adopted December 2025), influencing Swiss alignment

Suggested considerations

• Enhance customer due diligence (CDD): Review existing Russia/Ukraine portfolios for matches; implement enhanced monitoring for shadow fleet, oil traders, and FIMI-linked entities.
• Report to FINMA/SECO: Notify of any frozen assets or potential breaches; document compliance efforts to mitigate enforcement risks.
• Update policies: Integrate EU 18th package into internal sanctions frameworks, including red flags for circumvention (e.g., crypto, third-country banks).
• Train staff: Conduct urgent refreshers on secondary sanctions risks per FINMA Risk Monitor 2025.

What changed

• The core update involves Switzerland incorporating EU Council decisions from the 18th sanctions package, which typically include:
• Additions to asset freeze lists targeting Russian individuals, entities, and sectors like energy, finance, and dual-use goods.
• Expanded prohibitions on making funds or economic resources available to designated parties.
• Alignment with EU sectoral restrictions on Russia's financial messaging services (e.g., SPFS), oil trade, and shadow fleet activities, now binding in Switzerland via ordinances updated by WBF/SECO.

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.

Key dates

26 June 2025

- Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations

15 December 2025

- Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/

Ongoing (continuous) Deadline

- Annex updates published in Federal Gazette; firms must integrate changes without specified delay

Suggested considerations

• Immediate screening: Run updated Annex 2 against client databases, transactions, and assets; block and report any matches to FINMA via SR system.
• Enhanced due diligence: Review Guatemala exposures for links to designated parties (e.g., Public Prosecutor’s Office officials, FCT); suspend dealings and notify self-certification.
• System updates: Ensure sanctions screening tools (e.g., World-Check, Refinitiv) reflect changes; train staff and document compliance.
• Reporting: File suspicious activity reports (SARs) to MROS if pre-existing dealings detected; retain evidence of non-execution of prohibited transactions. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/

What changed

• - Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election...
• Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
• Updates are published in the Federal Gazette and integrated into FINMA's continuously maintained sanctions lists for automated screening.