Authorisation & Licensing in Switzerland

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 assets of 37 persons in the context of Venezuela, the January 13 update to SR 946.231.178.5 represents an amendment to Switzerland's broader sanctions ordinance framework. The specific changes to Annex 1 require Swiss entities to: Update their sanctions

What You Need To Do

• *Immediate Screening
• *Asset Identification
• *Freeze Implementation
• *Notification
• *Transaction Review

Key Dates

References

• [1] finma.ch
• [2] k2integrity.com
• [3] ofac.treasury.gov
• [4] clearygottlieb.com
• [5] complyadvantage.com
• [6] hklaw.com
• [7] finma.ch
• [8] hsfkramer.com

What Changed

Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously sanctioned under the Embargo Act. Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA provisions. Duration: The freeze is valid for four years until 4 January

What You Need To Do

• Screen and identify
• Freeze assets
• Report to MROS
• Internal updates
• Document compliance

Key Dates

References

• [1] finma.ch
• [2] news.admin.ch
• [3] sanctionsnews.bakermckenzie.com
• [4] clearytradewatch.com
• [5] euronews.com
• [6] finma.ch

What Changed

Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists. Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans. Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector. Fi

What You Need To Do

• Immediate screening
• Asset freezing
• Transaction halts
• Ongoing monitoring

Key Dates

References

• [1] finma.ch
• [2] bmwet.gv.at
• [3] finma.ch
• [4] finma.ch
• [5] vbw-bayern.de
• [6] seco.admin.ch
• [7] finma.ch
• [8] finma.ch

What Changed

Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine. Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening), financial services (e.g., transaction bans on additional banks), and energy sectors. Requirements for financial intermediaries to

What You Need To Do

• Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists)
• Freeze assets of newly sanctioned persons/entities and prohibit dealings (e
• Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist
• Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e
• Review third-party exposures (e

Key Dates

References

• [1] finma.ch
• [2] belarus.ahk.de
• [3] finma.ch
• [4] finma.ch
• [5] vbw-bayern.de
• [6] finma.ch
• [7] bafa.de
• [8] wbf.admin.ch

What Changed

Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election integrity, consistent with parallel EU actions. Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law. Updates are published in the Federal Gazette and integrated into FINMA'

What You Need To Do

• Immediate screening
• Enhanced due diligence
• System updates

Key Dates

References

• [1] finintegrity.org
• [2] steptoe.com
• [3] lupicinio.com
• [4] imf.org
• [5] alacosanctions.com
• [6] finma.ch
• [7] swlegal.com
• [8] finma.ch