Aktualisierte Sanktionsmeldung: Sudan

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. A sanctions report does not replace the obligation to conduct additional investigations where there are suspicions under Article 6 of the Swiss Anti-Money Laundering Act (GwG) and, where suspicions cannot be dispelled, to file an immedia

Who is affected

• Swiss banks and securities firms
• Swiss wealth managers and private banks
• Swiss asset managers and investment firms acting as financial intermediaries
• Swiss payment providers, crypto-asset intermediaries and other institutions subject to the GwG

Related regulations

• Ordinance of 25 May 2005 on Measures against Sudan (SR 946.231.18)
• Swiss Anti-Money Laundering Act, Article 6
• Swiss Anti-Money Laundering Act, Article 9