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Aktualisierte Sanktionsmeldung: Südsudan

AI Analysis

FINMA is notifying financial intermediaries that the Swiss sanctions list for **South Sudan** has been updated by the WBF, with the change entering into force at **23:00 on 11 August 2026**. For compliance teams, this means immediate sanctions screening, asset-freezing, and customer/business relationship review obligations apply to any newly listed or modified persons, entities, or organizations.

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.
  • File an immediate suspicious activity report to the MROS under Art. 9 GwG if suspicions cannot be resolved.

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 updated accordingly.
  • 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.
  • A SECO report does not replace anti-money laundering due diligence: if there are suspicion indicators, firms must carry out additional clarifications under Art. 6 AMLA/GwG and, if suspicions cannot be dispelled, file an immediate report to the Money

Compliance impact

The compliance impact is high because sanctions breaches can trigger immediate supervisory, civil, and criminal exposure, and the obligation to freeze assets is time-sensitive from the effective hour. Failure to identify a listed person or to escalate AML suspicion separately can create dual sanctions and AML reporting deficiencies.

Who is affected

  • Swiss financial intermediaries
  • Banks
  • Asset managers, wealth managers, and family offices
  • Broker-dealers and capital markets firms
  • Payment providers and fintech firms
  • Any firm with business relationships, assets, or transactions linked to persons, companies, or organizations on the updated South Sudan sanctions list.

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 eine Änderung des Anhangs 2 der Verordnung vom 12. August 2015 über Massnahmen gegenüber der Republik Südsudan (SR 946.231.169.9) publiziert.

Published by FINMA . Read the full notice at the source for the authoritative text.

Relevant Firm Types

BankAsset ManagerWealth ManagerPayment Provider
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