August 2025 Regulatory Updates

What Changed

The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG). The broader context shows that Switzerland was preparing for sig

What You Need To Do

• *Immediate compliance obligations
• *Sanctions List Screening
• *Transaction Review
• *Account Monitoring
• *Policy Updates

Key Dates

References

• [1] bex.ag
• [2] finma.ch
• [3] finma.ch
• [4] finma.ch
• [5] ad-hoc-news.de
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The core change is an amendment to the list of sanctioned natural persons, companies, and organizations in SR 946.231.149.82, as published by SECO. This reflects broader UN Security Council updates via Resolution 2769 (2025), which introduced new designation criteria for individuals/entities supporting armed groups or criminal networks through illicit exploitation/export of crude oil or refined petroleum from Libya, alongside exemptions for certain arms embargo activities, allowances for Libyan

What You Need To Do

• Screen immediately
• Freeze assets
• Cease dealings
• Update systems
• Monitor related flows

Key Dates

References

• [1] press.un.org
• [2] securitycouncilreport.org
• [3] steptoe.com
• [4] gov.je
• [5] gov.uk
• [6] ofac.treasury.gov
• [7] swlegal.com
• [8] state.gov

What Changed

SECO amended Annex 2 of the Ordinance, likely adding, removing, or modifying listings of sanctioned persons, companies, or organizations related to South Sudan. The update requires implementation of prohibitions (e.g., no new business), asset freezing for listed parties, and reporting of affected relationships to SECO. Changes stem from ongoing enforcement of UN and EU sanctions, with Switzerland implementing via the Embargo Act; Annexes are dynamically updated. #

What You Need To Do

• Screen client portfolios, transactions, and relationships against the updated SESAM database and Annex 2 via FINMA's website or MyFINMA portal
• Freeze assets of newly listed parties without delay; block prohibited transactions
• Report affected business relationships to SECO promptly; conduct additional GwG Art
• Update internal sanctions screening systems and train staff; document compliance for audit trails

Key Dates

References

• [1] finma.ch
• [2] seco.admin.ch
• [3] finma.ch
• [4] sif.admin.ch
• [5] finma.ch
• [6] finma.ch
• [7] arif.ch
• [8] finma.ch

What Changed

Amendment to Annex 2 of SR 946.231.18, which lists designated persons, entities, and assets subject to sanctions such as asset freezes and prohibitions on making funds or economic resources available. Updates reflected in the official Swiss sanctions database SESAM (SECO Sanctions Management), published on the SECO website, ensuring harmonized implementation across Switzerland. Urgent (dringliche) amendment entering into force immediately, bypassing standard consultation periods to address time-

What You Need To Do

• Screen against updated SESAM database
• Transaction screening and blocking
• Internal compliance update
• Reporting obligations
• Audit and evidence retention

References

• [1] finintegrity.org
• [2] assets.publishing.service.gov.uk
• [3] ofac.treasury.gov
• [4] finma.ch
• [5] press.un.org
• [6] gov.im
• [7] finma.ch
• [8] finma.ch

What Changed

Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk management for violations and circumvention. Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and report deficiencies. Screening and monitoring requirements: Maint

What You Need To Do

• Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly
• Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting
• Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e
• Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes
• Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions

References

• [1] cssf.lu
• [2] cssf.lu
• [3] stradalex.lu
• [4] cliffordchance.com
• [5] cssf.lu
• [6] elvingerhoss.lu
• [7] mondaq.com
• [8] forbes.lu

What Changed

The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Coun

What You Need To Do

• *Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
• *Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
• *Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
• *Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
• *Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements

Key Dates

References

• [1] bafu.admin.ch
• [2] steptoe.com
• [3] finintegrity.org
• [4] finma.ch
• [5] finma.ch
• [6] finma.ch
• [7] bakermckenzie.com
• [8] info4c.net

What Changed

The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19). Financial sanctions reinforce asset freezes, prohibitions on providing funds/services to listed parti

What You Need To Do

• Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e
• Conduct GwG Art
• Cease prohibited activities
• Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates
• For trade/energy firms

Key Dates

References

• [1] finma.ch
• [2] seco.admin.ch
• [3] finma.ch
• [4] finma.ch
• [5] finma.ch
• [6] peqsolutions.ch
• [7] bafa.de
• [8] finma.ch

What Changed

Updated Sanctions List: The WBF amended the Annex to include additional natural or legal persons, organizations, or entities subject to financial sanctions, effective immediately upon publication. Financial Sanctions Reinforced: Mandatory asset freezes (sperre von Vermögenswerten), prohibitions on making funds or economic resources available (Bereitstellungsverbote), and reporting requirements to SECO for frozen assets remain core, mirroring EU Regulation 2023/888 updates. No Change to Core Ordi

What You Need To Do

• Screen Client Base
• Freeze and Report Assets
• AML Due Diligence
• Internal Controls
• Monitor Ongoing

Key Dates

References

• [1] finma.ch
• [2] seco.admin.ch
• [3] wko.at
• [4] finma.ch
• [5] peqsolutions.ch
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The core update involves Switzerland incorporating EU Council decisions from the 18th sanctions package, which typically include: Additions to asset freeze lists targeting Russian individuals, entities, and sectors like energy, finance, and dual-use goods. Expanded prohibitions on making funds or economic resources available to designated parties. Alignment with EU sectoral restrictions on Russia's financial messaging services (e.g., SPFS), oil trade, and shadow fleet activities, now binding in

What You Need To Do

• Screen sanctions lists immediately
• Enhance customer due diligence (CDD)
• Report to FINMA/SECO
• Update policies
• Train staff

Key Dates

References

• [1] mrllp.com
• [2] finintegrity.org
• [3] mayerbrown.com
• [4] steptoe.com
• [5] finma.ch
• [6] finma.ch
• [7] sif.admin.ch
• [8] finma.ch