Aktualisierte Sanktionsmeldung: Russland
AI Analysis
The publication announces updates by the Swiss Federal Department for Economic Affairs, Education and Research (WBF) to Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions against Russia with ongoing international restrictions. This matters for Swiss financial intermediaries as it imposes immediate obligations to block assets, report relationships, and conduct AML checks, amid escalating sanctions that heighten compliance risks and enforcement scrutiny from FINMA.
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 dealings with the Russian Direct Investment Fund (RDIF).
Compliance impact
Urgency: Critical – Effective immediately at 23:00 on January 13, 2026, with no grace period, this demands urgent system updates, screenings, and reporting to avoid FINMA enforcement (e.g., fines, licenses at risk). It amplifies AML / Financial Crime risks in a high-scrutiny environment, as FINMA's Risikomonitor 2025 highlights Russia sanctions as a top concern amid iterative updates.
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.
What the FINMA said
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 8 der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
Published by FINMA . Read the full notice at the source for the authoritative text.