Aktualisierte Sanktionsmeldung: Venezuela

Key dates

January 5, 2026

- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons

January 13, 2026

- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)

Immediate Deadline

- Compliance obligations commence upon publication; no grace period for implementation

Suggested considerations

• *Immediate Screening: Conduct comprehensive screening of all client and counterparty databases against the updated Annex 1 designations within 24-48 hours of publication.
• *Asset Identification: Identify and document any assets, accounts, or positions held by or on behalf of newly designated persons/entities.
• *Freeze Implementation: Immediately freeze all identified assets and block all transactions involving designated parties.
• *Notification: Report any blocked assets to SECO as required under Swiss sanctions legislation (typically within 10 business days).
• *Transaction Review: Suspend all pending transactions with Venezuela-related counterparties pending compliance verification.
• *Systems Update: Update sanctions screening software and watchlists to reflect the revised designations.

What changed

• The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela. While the search results reference a separate FINMA ordinance (RS 196.127.85) adopted on January 5, 2026, which froze asset
• Update their sanctions screening systems with revised designations
• Identify any existing relationships with newly designated or de-designated persons/entities
• Implement immediate asset freezing for any newly added designations
• Cease all transactions with blocked parties unless specifically authorized

Who is affected

• *Primary stakeholders:
• Swiss banks and financial institutions
• Asset managers and wealth managers operating in Switzerland
• Payment service providers and money transmitters
• Insurance companies with Venezuelan exposure
• Any Swiss entity holding assets or conducting transactions involving Venezuela-related parties
• *Secondary stakeholders:
• Multinational firms with Swiss subsidiaries or operations

Related regulations

• *Swiss Regulatory Framework
• *U.S. Sanctions Alignment
• *Critical Compliance Distinction
• *AML/CFT Risk Profile
• driven predicate offenses2. This creates a practical constraint
• *Industry Guidance