On July 31, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) amended the annex to the Syria Asset Freezing Ordinance (SR 196.127.27), originally enacted March 7, 2025, to update the list of designated individuals subject to comprehensive asset freezes. This amendment reflects Switzerland's ongoing implementation of targeted financial sanctions against politically exposed persons connected to the former Assad regime, requiring immediate compliance from all financial intermediaries and asset holders operating in Swiss jurisdiction.
What Changed
The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices.
The amendment operates under the Federal Act on the Freezing and Restitution of Illicit
What You Need To Do
*Immediate compliance steps for financial institutions:
*Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
*Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
*File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
*Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities
Key Dates
March 7, 2025, 6:00 PM UTC– Original Syria Asset Freezing Ordinance entered into force
July 31, 2025, 6:00 PM UTC– Amendment to annex (list of designated persons) entered into force
Ongoing– Immediate freezing obligation upon designation; no grace period applies
Four-year validity– The ordinance remains valid for four years from March 7, 2025, unless extended or modified
Warning Savings protection Warning Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Warning Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Sanctions & settlements professional obligations Disclosure Obligations Other professionals Journalists The AMF Enforcement Committee fines a Danish investment bank for breaches of professional obligations committed by a French branch
AI Analysis
The AMF Enforcement Committee imposed a €300,000 fine on Saxo Bank A/S on 16 July 2025 for multiple breaches of professional obligations committed through its French branch, including failures to properly inform clients about significant changes to derivatives procedures, margin calculations, and securities transaction incidents, as well as deficiencies in equity savings plan (PEA) transfers. This enforcement action demonstrates the AMF's active oversight of cross-border investment banks operating in France and highlights critical gaps in client disclosure practices that compliance teams must address.
What Changed
The enforcement decision does not introduce new regulatory requirements but rather clarifies existing obligations under current French financial regulations. The key compliance expectations reinforced include:
Client notification requirements for significant procedural changes affecting derivatives trading and margin calculations
Incident disclosure obligations for securities transactions that could materially affect order execution
Timely information provision regarding regulatory consequences
What You Need To Do
*Implement incident reporting protocols for securities transactions that could affect order execution, with documented evidence of timely client notification
*Review PEA transfer procedures to ensure compliance with regulatory timeframes and proper documentation of information provided to clients regarding Brexit-related consequences
*Strengthen information governance to ensure all material operational changes are communicated to clients within required timeframes and with appropriate detail
*Conduct compliance training for front-office and operations staff on professional obligations regarding client communication and information disclosure
Key Dates
16 July 2025- AMF Enforcement Committee decision issued imposing €300,000 fine
22 July 2025- Official publication of enforcement decision
No specified deadline- Appeal period available (no specific timeframe stated in the decision)
MAR Financial disclosures & corporate financing Shares The AMF and the AFA call for vigilance of the risk of private corruption by criminal networks of natural persons with access to inside information
Sanctions & settlements MAR professional obligations Investment advice Other professionals Journalists Listed companies and issuers The AMF Enforcement Committee fines eight individuals and two legal entities a total of €1,890,000 for late...
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
AI Analysis
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
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What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring mod
What You Need To Do
Monitor developments
Review internal practices
Enhance documentation
Engage stakeholders
Key Dates
2024- Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025- Report published for public consultation.
14 March 2025- Industry responses submitted (e.g., GDF, Adan).
16 July 2025- Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Thomas Hirschi has decided to leave the Swiss Financial Market Supervisory Authority FINMA effective 31 August 2025. The Head of the Banks division will pursue a new career outside FINMA. FINMA’s Board of Directors and Executive Board thank Thomas Hirschi for his valuable contribution during his time at FINMA.
Supervision Governance Sustainable Finance Journalists Investment management companies The AMF publishes a summary of its SPOT inspections on asset management companies' voting and engagement policies
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
AI Analysis
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Haiti (SR 946.231.139.4), dated December 16, 2022, aligning Switzerland's sanctions regime with recent UN Security Council decisions. This matters for Swiss financial institutions as it mandates immediate screening against potentially updated lists of designated persons and entities, reinforcing asset freezes, travel bans, and an expanded arms embargo to address Haiti's instability. Non-compliance risks FINMA enforcement actions under anti-money laundering and sanctions frameworks.
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What Changed
Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in destabilizing activities like illicit natural resource exploitation, as seen in parallel UN actions (e.g., 2 new entries added on October 17/20, 2025).
Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing
What You Need To Do
Screen Immediately
Cease Prohibited Activities
Report Findings
Update Policies/Systems
License Checks
Key Dates
October 18, 2024 - UNSC Resolution 2752 adoptionExpands arms embargo scope, basis for national implementations.
July 23, 2025 - UK Haiti Sanctions Amendment effectiveParallel indicator of timeline for UN-aligned changes.
October 17/20, 2025 - UNSC Committee adds 2 entries to Sanctions ListTriggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response.
October 21, 2025 - Swiss WBF/VTG announcementConfirms amended sanctioned list.
Immediate/publication date (2025/07/09 per FINMA notice) - Swiss Annex amendment effectiveNo grace period specified; aligns with "without delay" freezing requirements.
Compliance Impact
Urgency: High – Immediate asset freeze obligations apply "without delay" upon list updates, with FINMA's enforcement type indicating potential fines or reputational damage for lapses; matters due to Haiti's volatility driving frequent UN changes, risking secondary sanctions exposure for Swiss firms
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MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body
Risk and Trend Mapping Markets Fixed income Asset management Other professionals Executive & other private individuals Fintech The AMF publishes its 2025 Markets and Risk Outlook
On 3 July 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultations on the new Ordinances on the Risk Diversification of Banks and Securities Firms and on the Liquidity of Banks and Securities Firms. The consultations will go on until 29 September 2025.