Key dates
- 08 June 2012
- - Original Ordinance on Measures against Syria (SR 946.231.172.7) entered into force, establishing the sanctions framework and Annex 7
- 15 June 2026
- - WBF amended the list of sanctioned persons, companies, and organisations in Annex 7 of the Syria sanctions ordinance and updated the Swiss SESAM sanctions database; SECO published the updated list on its website
- 16 June 2026 Deadline
- - The amended measures, including changes to the Annex 7 Syria sanctions list, enter into force at 23:00, from which time financial intermediaries must fully apply the new listings and obligations
Suggested considerations
- Perform an immediate update of sanctions screening lists and tools to incorporate the revised Syria Annex 7 entries as reflected in the SESAM database.
- Identify all customers, beneficial owners, counterparties, and transactions that match or potentially match the updated Syria sanctions list, including retrospective screening where systems permit.
- Freeze without delay all assets and economic resources held or controlled by persons, entities, or organisations that are newly listed or affected by changes under the updated Annex 7.
- Block any new or pending transactions that would make funds or economic resources available, directly or indirectly, to persons and entities designated under the updated Syria list.
- Report all affected business relationships and frozen assets to SECO in accordance with the reporting requirements of the Syria sanctions ordinance and SECO guidance.
What changed
- - The WBF has amended Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7), changing the list of sanctioned persons, companies, and organisations connected to Syria.
- The Swiss sanctions database SESAM (SECO Sanctions Management) has been updated to reflect these changes, and SECO has published the amended list on its website.
- The updated measures, including asset-freeze and prohibition obligations, enter into force on 16 June 2026 at 23:00, making the revised Syria list immediately enforceable for Swiss-supervised...
- Financial intermediaries are explicitly required to implement the applicable prohibitions, including restrictions on making funds or economic resources available to listed persons, entities, and...
- Financial intermediaries must freeze the assets and economic resources of the persons, companies, and organisations newly listed, relisted, or otherwise affected by the Annex 7 amendment.
Compliance impact
Non-compliance exposes firms to FINMA enforcement measures, including coercive administrative actions, reputational damage, and potentially severe regulatory sanctions for failures in sanctions implementation and AML controls. Breaches of Swiss sanctions and AML obligations can also create criminal liability risks for institutions and responsible individuals, particularly where prohibited economic resources are made available or suspicious activity is not reported.