Capital Markets & Trading in Switzerland

What Changed

The total revision introduces several critical regulatory shifts: *Scope Expansion**: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803, 1835, 1929, and 2224) and aligns Swiss sanctions with EU measures reactivated on September 29, 2025. *Sectoral Restrictions**: New measures in the raw materials sector have been introduced, complementing existing prohibitions on: Sale or supply of key energy sector equipment Gold, precious metals

What You Need To Do

• *Immediate (Completed by December 12, 2025)
• related transactions and accounts for compliance with expanded prohibitions
• *Short-term (By January 1, 2026)
• September 30, 2025 contracts under legacy exemption provisions
• related transactions

Key Dates

References

• [1] finma.ch
• [2] news.admin.ch
• [3] efd.admin.ch
• [4] finma.ch
• [5] ihk.de
• [6] wko.at
• [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

*Financial Sector Restrictions** The Bundesrat expanded transaction prohibitions on Russian banks substantially: Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions Introduced new transaction prohibitions for 22 additional Russian banks Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previou

What You Need To Do

• *Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
• *Freeze assets of all sanctioned persons and entities immediately upon notice
• *Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
• *Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
• *Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy

Key Dates

References

• [1] finma.ch
• [2] finma.ch
• [3] bundesregierung.de
• [4] finma.ch
• [5] noerr.com
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically: Previous deadline: January 1, 2026 New deadline: January 1, 2029 Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or recognized central counterparty Regulatory basis: FINMA Guidanc

What You Need To Do

• *Acknowledge the extended timeline
• *Maintain risk management controls
• *Monitor FinMIA revision
• *Document compliance rationale
• *Assess competitive positioning

Key Dates

References

• [1] charltonsquantum.com
• [2] finma.ch
• [3] charltonsquantum.com
• [4] finma.ch
• [5] practiceguides.chambers.com
• [6] finma.ch
• [7] pwc.ch
• [8] swlegal.com

What Changed

Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement. Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs). These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additio

What You Need To Do

• Screen and freeze assets
• Report to SECO
• Conduct AML due diligence
• Review transactions
• Document compliance

References

• [1] finma.ch
• [2] finma.ch
• [3] finma.ch
• [4] finma.ch
• [5] finma.ch
• [6] finma.ch
• [7] finma.ch
• [8] ochsner-consulting.com