FINMA Updates 2026

Key dates

2026-11-03

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

2026-11-04

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

2026-11-04

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

2026-11-05

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

Suggested considerations

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

What changed

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

Key dates

2025-11-26

FINMA published its ex-post evaluation of Circular 2019/2, identifying potential improvements to proportionality and validation requirements and announcing a planned partial revision.

2026-11-04

FINMA launched the consultation on the partial revision of Circular 2019/2.

2027-01-15 Deadline

The FINMA consultation period closes; consultation responses should be submitted by this date.

Suggested considerations

• Banks should review the consultation package and consider submitting comments to FINMA by 15 January 2027, particularly on proportionality, validation burden, earnings-risk metrics and implementation timing.
• Risk and finance teams should perform an impact assessment using the Basel Committee’s July 2024 recalibrated shock methodology, including the potential effect of 25-basis-point rounding and updated historical calibration data.
• Banks should map current interest-rate-risk models, independent validation procedures and model governance against the expected clarification of minimum validation requirements.
• Compliance teams may wish to reassess whether the institution’s proportionality framework appropriately differentiates requirements by size, business model, complexity and risk profile, while retaining evidence supporting those judgments.
• Treasury and risk functions should assess whether existing interest-rate-risk reporting captures both economic-value effects and effects on net interest income or other relevant revenue measures.
• Governance bodies should record the consultation assessment, scenario-analysis results, model changes and any decision to submit industry comments, while continuing to apply the currently effective Circular 2019/2 until a final revision enters into force.

What changed

The proposed revision would update the standardised interest-rate shock scenarios used to measure interest-rate risk in the banking book, reflecting the Basel Committee’s July 2024 recalibration. The Basel recalibration uses updated historical data, a 99.9th-percentile shock-factor methodology and shock values rounded to 25 basis points; the Basel standard contemplated implementation from 1 January 2026, but the Swiss implementation timeline will depend on FINMA’s final circular.

Key dates

2026-11-02

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

2026-11-03 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-10-08

FINMA published the final partial revision of Circular 2016/7.

2026-11-01 Deadline

The revised Circular 2016/7 enters into force and the new supervisory expectations for digital onboarding apply.

2027-11-01 Deadline

Market commentary reports a transitional deadline for firms using qualified electronic signatures to add liveness detection and residence verification.

Suggested considerations

• Compliance teams should map each digital onboarding journey to the revised Circular 2016/7 method requirements, distinguishing video identification, online identification, Swiss e-ID and qualified electronic-signature workflows.
• Firms should assess whether their liveness-detection controls reliably establish that the applicant is a physically present living person and can resist photographs, replayed video, deepfakes and other AI-enabled manipulation.
• Firms should review identity-document validation rules and testing so that approved QR-code documents, including the Swiss driving licence, are handled on an equivalent basis to documents with an MRZ where the circular permits this.
• Firms should validate digital residence-verification processes, including whether the process reliably links the contracting party and the relevant device or infrastructure to the declared place of residence.
• Firms planning to use the Swiss e-ID should confirm technical readiness, evidence retention and treatment of the e-ID's non-copyable, non-archivable characteristics, while avoiding use of the e-ID for workflows limited to video identification.
• Firms should update AML, fraud-risk and onboarding policies, vendor requirements, testing scripts, staff procedures and customer disclosures before the effective date.
• Compliance teams may wish to reassess whether supplementary controls are warranted for higher-risk channels, such as device intelligence, fraud databases, transfer-account verification, duplicate-account detection or enhanced review, because FINMA's circular does not eliminate risk-based control expectations.
• Firms using qualified electronic signatures should confirm any transitional implementation requirements identified in the final circular and related commentary, including the reported 1 November 2027 date for adding liveness and residence verification to that route.

What changed

The Swiss e-ID may be used as an identification method when onboarding clients through digital channels under the Anti-Money Laundering Act, although market commentary indicates that it is available for online identification rather than video identification. Official identification documents bearing a QR code are treated as equivalent to documents containing a machine-readable zone, expanding the acceptable document formats for digital onboarding.

Key dates

2026-05-22

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

2026-08-19

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

2026-08-20 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-08-18

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

2026-08-19

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

2026-08-20

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

Suggested considerations

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

What changed

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

Key dates

2026-08-14

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

2026-08-17

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

2026-08-19

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

Suggested considerations

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

What changed

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

Key dates

2026-08-17

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

2026-08-18 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-08-14

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

2026-08-17 Deadline

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

Suggested considerations

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

What changed

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

Key dates

2026-08-13

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

2026-08-14

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

2026-08-17

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

Suggested considerations

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

What changed

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

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

25 May 2005

- Erlass der Verordnung über Massnahmen gegenüber Sudan (SR 946.231.18), die den rechtlichen Rahmen für schweizerische Sudan-Sanktionen schafft

04 June 2026

- Das WBF beschliesst und veröffentlicht die Änderung des Anhangs 2 der Verordnung über Massnahmen gegenüber Sudan (SR 946.231.18); die aktualisierte Sanktionsliste tritt in Kraft und ist ab diesem Datum anzuwenden

Suggested considerations

• Führen Sie umgehend einen Abgleich aller Kunden-, Konten- und wirtschaftlich Berechtigten-Stammdaten sowie relevanter Transaktionen gegen die aktualisierte Sudan-Sanktionsliste gemäss Anhang 2 der Verordnung SR 946.231.18 durch.
• Identifizieren und dokumentieren Sie alle Treffer (Hits) zu gelisteten Personen, Organisationen oder Einrichtungen und prüfen Sie diese formal (True Hit vs. False Positive) unter Anwendung eines dokumentierten, vier-Augen-prüfenden Verfahrens.
• Frieren Sie Vermögenswerte von bestätigten gelisteten Personen oder Einrichtungen unverzüglich ein, blockieren Sie Transaktionen und verhindern Sie jede direkte oder indirekte Bereitstellung von wirtschaftlichen Ressourcen, in Übereinstimmung mit der Sudan-Verordnung.
• Erstatten Sie umgehend die erforderlichen Meldungen an die zuständigen Bundesstellen (insbesondere SECO bzw. die im Sanktionsrecht vorgesehenen Behörden) sowie – soweit einschlägig – Verdachtsmeldungen an die Meldestelle für Geldwäscherei (MROS).
• Aktualisieren Sie Ihre Sanktions- und AML-Richtlinien, Arbeitsanweisungen und Kontrollpläne, um die neuen Sudan-spezifischen Listungen und Prozesse zur Vermögenssperre und Meldung explizit zu berücksichtigen.

What changed

• - Der Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) wurde durch Entscheid des WBF aktualisiert, was Änderungen an der Sanktionsliste (gelistete natürliche...
• Die aktualisierte Sanktionsliste zu Sudan ist für alle von der Verordnung erfassten Finanzintermediäre unmittelbar verbindlich und ist bei der Prüfung von Kunden, wirtschaftlich Berechtigten,...
• Vermögenswerte von neu gelisteten Personen oder Einrichtungen müssen gemäss Verordnung unverzüglich eingefroren und dürfen weder direkt noch indirekt zur Verfügung gestellt werden.
• Bereits bestehende Geschäftsbeziehungen zu neu gelisteten Personen oder Einrichtungen sind zu suspendieren bzw. abzuwickeln, soweit dies mit den gesetzlichen Vermögenssperren vereinbar ist.
• Institute sind verpflichtet, gefundene Treffer (Treffer bei Konten, Depots, Zahlungs- oder Handelsgeschäften) zu gelisteten Personen oder Einrichtungen den zuständigen Bundesstellen nach den...

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

19 March 2026

- WBF amends Annex 8, removing 7 natural persons

20 March 2026, 23:00 UTC Deadline

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

Suggested considerations

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

What changed

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

Key dates

March 19, 2026

- WBF amends Annex 8 and publishes the update

March 20, 2026, 23:00 Uhr Deadline

- Changes enter into force; sanctions screening and asset handling must reflect delistings immediately thereafter

Suggested considerations

• Screen and release assets: Review client portfolios and frozen assets linked to the 7 delisted persons; release any previously frozen assets unless other sanctions apply (e.g., via GwG AML checks).
• Update internal systems: Refresh sanctions screening tools with the latest SESAM data to avoid erroneous freezes or compliance breaches.
• Report to SECO if applicable: If assets were frozen and are now releasable, notify SECO of prior relationships; conduct GwG Art. 6 due diligence and report suspicions to the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
• Document changes: Maintain audit trails of screening adjustments to demonstrate compliance with ongoing supervisory obligations.

What changed

• - Removal of 7 natural persons from Annex 8, which lists designated individuals subject to asset freezes and other restrictive measures related to the Ukraine situation.
• Update to the SESAM sanctions database (SECO Sanctions Management), Switzerland's authoritative list aligned with EU sanctions.
• No new designations or additional prohibitions introduced; this is a delisting that narrows the scope of sanctions application.

Key dates

March 9, 2026

– WBF published updated sanctions list and modified SESAM database

March 10, 2026, 23:00 UTC

– Effective date for all regulatory changes (enforcement begins)

Immediate Deadline

– Financial intermediaries must implement prohibitions and freeze assets upon effectiveness

Suggested considerations

• *Implement Prohibitions: Execute all transaction bans and restrictions specified in the updated ordinance annexes
• *Asset Freezing: Immediately freeze all assets and funds of sanctioned persons, enterprises, and organizations identified in the updated SESAM database
• *Mandatory Reporting to SECO: Report all affected business relationships to the State Secretariat for Economic Affairs within required timeframes
• *Enhanced Due Diligence: Conduct additional investigations under Article 6 of the Anti-Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious Activity Reporting: If enhanced due diligence cannot eliminate suspicions, file mandatory reports with the Money Laundering Reporting Office (Meldestelle für Geldwäscherei) under Article 9 GwG without delay

What changed

• The regulatory update encompasses four substantive modifications:
• Annex 3: Expansion of the goods list subject to export/import restrictions
• Annexes 12, 13, and 14: Updates to the list of sanctioned persons, enterprises, and organizations subject to asset freezing and transaction prohibitions
• SESAM Database: The Swiss sanctions management database (SECO Sanctions Management) has been updated to reflect all changes, published urgently on the WBF website The changes represent a total...

Key dates

2022

- FINMA had already proposed introducing an accountability regime to define managers’ roles and responsibilities more clearly

Summer 2023

- An expert report renewed the call for fines, clearer senior-management responsibility, and greater enforcement transparency

Spring 2024

- The Federal Council’s TBTF report again carried forward these reform themes

End of 2024

- The Parliamentary Investigation Commission report recommended strengthening enforcement effectiveness and transparency

Summer 2025

- The Federal Council set parameters for upcoming legislative reforms including these enforcement-related measures

Suggested considerations

• Review governance maps and delegations to ensure each regulated activity, key control, and approval step is assigned to a clearly identified accountable senior manager.
• Document senior-management responsibilities in a manner that would withstand a future accountability-regime review, including decision rights, escalation duties, and oversight obligations.
• Stress-test enforcement readiness by preparing for formal FINMA proceedings that may end in binding rulings, remediation orders, or publication.
• Update incident-response and remediation workflows so that suspected supervisory-law breaches are escalated, investigated, and corrected quickly and with a complete evidence trail.
• Assume greater reputational exposure in enforcement cases and review internal communications, disclosure controls, and media-response protocols accordingly.

What changed

• - FINMA is again advocating a statutory power to impose fines for serious supervisory-law breaches, which it says would strengthen deterrence and enforcement effectiveness.
• FINMA is again calling for a clearer allocation of responsibility among senior management, consistent with an accountability regime or senior managers’ regime.
• FINMA is again seeking the right to inform the public about concluded enforcement proceedings involving serious rule violations, rather than being restricted to anonymous statistics and exceptional...
• FINMA reiterates that it already uses formal enforcement proceedings to clarify facts and restore compliance, with measures concluded by a ruling.
• FINMA states that, under current law, it may generally only publish anonymous enforcement statistics and individual case disclosures only where there is a particular supervisory interest.

Key dates

12 December 2025

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

13 December 2025

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

26 February 2026

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

Suggested considerations

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

What changed

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

Key dates

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

February 23, 2026

– SECO publishes Annex 8 amendments on its website

February 24, 2026, 11:00 PM UTC Deadline

– Changes take effect; financial intermediaries must immediately implement all prohibitions

H2 2026

– New organizational obligations under revised Money Laundering Act (GwG) requiring sanctions violation prevention measures take effect

Suggested considerations

• *Implement all prohibitions specified in updated Annex 8 across all business lines and customer relationships
• *Freeze assets of all newly designated natural persons and entities; block transactions with designated entities
• *Report to SECO all affected business relationships within required timeframes, documenting:
• Customer identification and beneficial ownership
• Transaction history with designated parties

What changed

• The February 2026 update to Annex 8 of the Ukraine Sanctions Ordinance introduces modifications to Switzerland's designated persons and entities list related to Russia sanctions.
• 22 natural persons and 42 companies/organizations subject to asset freezes and supply prohibitions
• 116 vessels (primarily tankers in Russia's shadow fleet circumventing oil price caps) subject to purchase, sale, and service prohibitions
• 45 companies in third countries subject to stricter export controls targeting critical goods for Russia's military-industrial complex
• 5 Russian banks and 4 foreign branches subject to transaction prohibitions due to use of Russian payment systems

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 29, 2026

– SECO publishes amended Annex 28 of the Sanctions Ordinance

February 1, 2026

– New oil price cap (USD 44.1) becomes effective and binding

Immediate Deadline

– Financial intermediaries must implement updated prohibitions and screening procedures

Suggested considerations

• *Implement price cap enforcement: Update transaction monitoring systems to flag and block crude oil transactions exceeding USD 44.1 per barrel from Russian sources
• *Asset freezing: Continue blocking assets of sanctioned persons and entities; verify no new transactions circumvent the lower threshold
• *Reporting obligations: Report affected business relationships to SECO in accordance with the Sanctions Ordinance
• *Enhanced due diligence: Beyond SECO reporting, conduct additional investigations under Article 6 of the Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious activity reporting: If enhanced due diligence cannot resolve suspicions, file reports with the Financial Intelligence Unit (FIU) under Article 9 GwG without delay

What changed

• The primary regulatory change is a downward adjustment of the Russian crude oil price cap:
• Previous cap: USD 47.6 per barrel
• New cap: USD 44.1 per barrel
• Effective date: February 1, 2026 This modification targets Russia's shadow fleet and circumvention mechanisms.

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

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

- Prior amendment effective dates, illustrating pattern of rapid implementation

January 13, 2026

- Publication of amendments by WBF, triggering immediate review obligations

November 22, 2026

- Current expiry of ordinance (subject to extension)

Suggested considerations

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

What changed

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

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.