Aktualisierte Sanktionsmeldung: Islamischen Republik Iran

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

October 20, 2025

- WBF incorporated updated UN Security Council listings

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
• *Policy Updates: Revise internal sanctions compliance policies to reflect the expanded scope of restrictions (nuclear technology, weapons, financial services, aviation)

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 revision of Iran sanctions regulations, reverting to the sanctions regime that existed before the 2015 Vienna Agreement on Iran's nuclear program. This December revision incorporated the UN Security Coun

Who is affected

• *Primary stakeholders:
• Swiss banks and financial institutions handling cross-border transactions
• Investment managers and wealth managers with Iranian counterparties or assets
• Trading firms and commodity brokers
• Insurance companies with Iranian exposure
• Payment service providers
• Any Swiss company engaged in trade with Iran
• *Secondary stakeholders:

Related regulations

• *Regulatory Developments
• EU Response
• Swiss Harmonization
• Geopolitical Divide
• Practical Implementation Challenges
• *Key Regulatory Sources