Aktualisierte Sanktionsmeldung: Ukraine
AI Analysis
FINMA is notifying market participants that the Swiss WBF amended **Annexes 2 and 8** of the Ukraine sanctions ordinance, with the changes published on the WBF website and entering into force **today at 23:00**. For compliance teams, this is an immediate sanctions-screening and asset-freezing event: firms must implement the updated prohibitions, freeze any affected assets, and notify **SECO** of impacted business relationships. This update also reinforces that a SECO notification does **not** replace the obligation to conduct further clarifications under **Article 6 AMLA/GwG** or to file a suspicious activity report with **MROS** under **Article 9 AMLA/GwG** if suspicion cannot be dispelled.
Key dates
- 10 August 2026
- - The WBF amended Annexes 2 and 8 of the Ukraine sanctions ordinance and published the changes on its website
- 12 August 2026 Deadline
- - The amended measures are published by FINMA and become operationally relevant for compliance teams
- 12 August 2026, 23:00
- - The amended sanctions measures enter into force
Suggested considerations
- Firms must immediately screen customers, counterparties, and beneficial owners against the updated Annex 2 and Annex 8 listings and identify any matches.
- Firms must block and freeze any assets or economic resources belonging to sanctioned persons covered by the updated ordinance.
- Firms must report the affected business relationships to SECO in accordance with the ordinance.
- Firms must perform additional fact-finding under Article 6 GwG/AMLA whenever the sanctions hit or surrounding facts create suspicion that cannot be dismissed.
- Firms must submit an immediate suspicious activity report to MROS under Article 9 GwG/AMLA if the suspicion remains unresolved after additional clarifications.
- Firms must update internal sanctions lists, screening rules, and transaction-monitoring scenarios to reflect the amended Ukrainian sanctions measures.
What changed
- - The WBF amended Annex 2 and Annex 8 of the Swiss ordinance on measures connected with the situation in Ukraine, updating the sanctions list and/or restrictions applicable under SR 946.231.176.72.
- The amended measures become effective today at 23:00, meaning firms must be ready to apply the updated prohibitions without delay.
- Financial intermediaries must implement the prohibitions contained in the ordinance, which includes sanctions-related restrictions beyond ordinary asset freezes.
- Financial intermediaries must freeze the assets of sanctioned persons covered by the update.
- Financial intermediaries must report affected business relationships to SECO.
- A SECO notification does not eliminate the duty to carry out additional clarifications under Article 6 GwG/AMLA when suspicion arises.
Compliance impact
The compliance impact is high because the measure has immediate effect and requires rapid screening, freezing, and reporting actions. Failure to implement the updated sanctions can lead to supervisory action, breaches of Swiss sanctions law, and potential AML enforcement exposure where institutions fail to escalate unresolved suspicions to MROS.
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 2 und 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.