Aktualisierte Sanktionsmeldung: Islamische Republik Iran

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. Under Article 16 of the ordinance, assets and economic resources owned or controlled by persons and entities covered by the relevant annexes must be frozen, and funds or economic resources must not be made available directly or indirectly where the applicable prohibition applies. The broader existing framework also includes Article 21 repo

Who is affected

• Swiss banks and other Swiss-domiciled financial intermediaries
• Swiss wealth managers and private banks
• Swiss payment providers and institutions processing Iran-related transfers
• Swiss asset managers, securities firms and other intermediaries holding client assets or business relationships involving listed persons or entities

Related regulations

• Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran (SR 946.231.143.6), particularly Article 16 and Article 21
• Federal Act on the Implementation of International Sanctions (Embargo Act; EmbA)
• Federal Act on Combating Money Laundering and Terrorist Financing (AMLA; GwG), Articles 6 and 9