Payments & E-Money in Switzerland

Key dates

2026-05-22

Switzerland added 115 natural persons and organisations to its Russia-related sanctions list; approximately 2,790 persons, companies, and organisations are now subject to asset freezes in connection with Russia’s war against Ukraine.

2026-08-19

The Federal Council decided to adopt the further measures of the EU’s 20th Russia sanctions package according to Switzerland’s established practice.

2026-08-20 Deadline

The new measures entered into force, including the prohibition on using Russian platforms for crypto-asset transfers and exchanges and the prohibition on supporting development of specified Russian crypto-assets such as the digital rouble.

Suggested considerations

• Firms should consider updating sanctions screening rules, prohibited-platform lists, wallet and counterparty controls, and transaction-monitoring scenarios to identify Russian crypto-asset platforms and indirect use of those platforms.
• Crypto-asset firms should consider mapping all transfer, exchange, custody, brokerage, technical-support, wallet-access, and infrastructure services against the applicable provisions of the Ordinance on Measures connected with the Situation in Ukraine, including the newly prohibited Russian platforms and specified Russian crypto-assets.
• Compliance teams may wish to review exposure to the digital rouble and other Russian or rouble-linked crypto-assets, including holdings, listings, liquidity provision, development support, transfers, and third-party integrations, and document any required exit or blocking decisions.
• Firms should consider validating that assets of sanctioned natural persons, companies, and organisations are blocked and that affected business relationships are reported to SECO in accordance with the sanctions ordinance.
• Firms should consider establishing or refreshing procedures for prompt escalation of sanctions-related suspicions, including additional clarifications under Article 6 GwG and an immediate Article 9 GwG report to the Money Laundering Reporting Office where suspicions cannot be dispelled.
• Senior compliance and operations owners may wish to evidence implementation from 2026-08-20 through control attestations, blocked-transaction testing, vendor and platform due diligence, and documented review of open Russian-related relationships.

What changed

The Switzerland-Russia sanctions regime now prohibits the use of Russian platforms for crypto-asset transfers and exchanges, targeting alternative payment channels that could facilitate sanctions circumvention. It also prohibits support for the development of specified Russian crypto-assets, including the digital rouble; independent market commentary places this measure alongside restrictions concerning Russian crypto-asset service providers, sanctioned trading venues, wallet or account access, technical assistance, and certain rouble-backed assets such as RUBx and A7A5, although the FINMA...

Key dates

2026-08-18

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland.

2026-08-19

SECO updated the SESAM database and published the Swiss sanctions-list adjustment.

2026-08-20

FINMA published the updated sanctions notice describing the amendment and related financial-intermediary obligations.

Suggested considerations

• Compliance teams may wish to obtain the 2026-08-19 SESAM update and identify precisely which persons, companies or organisations were added, amended or removed.
• Firms should consider refreshing sanctions-screening data and screening customers, beneficial owners, counterparties, payment parties, securities positions and existing business relationships against the amended entries without delay.
• Where a potential match is identified, firms should consider applying the relevant prohibitions, preventing disposal or transfer of assets, documenting the match analysis and escalating the case under their sanctions procedures.
• Firms should consider reporting affected business relationships and frozen assets to SECO in accordance with SR 946.231.08 and retaining evidence of the report and asset-freeze decision.
• A SECO sanctions report should not be treated as a substitute for AML controls; where indicators give rise to suspicion, compliance teams may wish to conduct the additional clarifications required by Article 6 GwG and file an immediate MROS report under Article 9 GwG if the suspicion cannot be dispelled.
• Firms with delegated or outsourced screening may wish to verify that vendors refreshed their Swiss sanctions data after 2026-08-19 and that payment and transaction-monitoring controls cover the amended list.

What changed

The sanctions list under the Swiss Ordinance of 2025-03-21 on measures against persons and organisations associated with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) was amended following the UN committee decision of 2026-08-18. The publication does not identify the amended entries or specify whether they are new designations, amendments or delistings; firms should therefore reconcile the current SESAM data against their prior screening population. The amendment applies in Switzerland directly and without a separate Swiss legislative adoption step.

Key dates

2026-08-14

The competent UN sanctions committee amended the ISIL (Da’esh) and Al-Qaida sanctions list; the amendment became directly applicable in Switzerland under the applicable automatic-implementation framework.

2026-08-17

SECO updated the Swiss-authoritative SESAM sanctions database and published the corresponding list adjustment.

2026-08-19

FINMA published its notice reporting the SECO sanctions-list update.

Suggested considerations

• Compliance teams may wish to retrieve the 17 August 2026 SESAM update and reconcile it against the prior list, recording all additions, removals and amendments and preserving the source version used.
• Firms should consider rerunning customer, beneficial-owner, counterparty, payment, trade and custody screening against the amended list, including historical transactions and open orders where their risk-based controls require retrospective review.
• Firms should consider reviewing transliterations, aliases, dates of birth, nationality, incorporation data and other identifiers for any newly listed individual or entity to reduce false negatives and false positives.
• Where a potential match is identified, firms should consider applying the prohibitions and asset-freeze requirements under SR 946.231.08, escalating the case under their sanctions procedures and assessing whether notification to SECO is required.
• Compliance teams may wish to verify that vendor feeds, transaction-screening systems, watchlists, case-management workflows and manual escalation procedures reflect the direct-applicability model and the 17 August SESAM update date.
• Firms should consider documenting the timing of list ingestion, screening completion, disposition of alerts, any blocked or frozen assets, and any reports or licence requests submitted to SECO for audit and supervisory purposes.

What changed

The UN sanctions committee changed the list of sanctioned individuals, companies and organisations covered by SR 946.231.08. Switzerland applies the change directly, without a separate Swiss legislative or regulatory adoption step. SECO updated SESAM, the SECO Sanctions Management database described as authoritative for Switzerland, on 17 August 2026 and published the amendment on its website.

Key dates

2026-08-17

EAER amended Annexes 12, 13 and 14 and SECO updated the SESAM sanctions database.

2026-08-18 Deadline

The amendment became legally effective at 23:00 Swiss time; affected prohibitions, asset freezes and SECO reporting obligations applied from that time.

Suggested considerations

• Compliance teams may wish to obtain the effective 2026-08-18 23:00 SESAM dataset and run an immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, payment beneficiaries, securities positions and relevant transaction history.
• Firms should consider applying the Article 16 asset-freeze and availability prohibitions to positive matches, including assets or economic resources controlled indirectly, and escalating potential matches for ownership-and-control analysis rather than relying only on exact-name screening.
• Financial intermediaries should consider reporting affected business relationships and frozen assets to SECO without delay in accordance with the ordinance, while documenting the screening timestamp, match disposition, freeze decision and notification trail.
• Teams may wish to review pending and recurring Iran-related payments against Article 21, including the CHF 10,000 SECO reporting threshold, the five-working-day reporting period, and the CHF 50,000 prior-authorisation threshold.
• A SECO sanctions report should not be treated as a substitute for AMLA analysis: where circumstances create suspicion, firms should consider additional clarifications under Article 6 AMLA/GwG and an immediate MROS report under Article 9 AMLA/GwG if the suspicion cannot be dispelled.
• Firms should consider reviewing delisted and amended entries separately, because removal from an Iran annex does not necessarily resolve exposure under other Swiss, UN or foreign sanctions regimes or eliminate unrelated AML, proliferation-financing or reputational-risk concerns.
• Compliance and operations teams may wish to confirm that screening vendors, payment filters, case-management workflows, correspondent-bank controls and sanctions procedures recognise the 23:00 Swiss-time effective moment and preserve an auditable change-management record.

What changed

The amendment updates the Swiss SESAM sanctions database and the designation annexes of the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran. Six individuals were delisted, one entity record was amended, and two individuals and one entity were newly listed; the publication does not identify the parties in the FINMA notice itself, so firms should rely on the current SECO SESAM data rather than the notice's entry counts alone.

Key dates

2026-08-13

The competent UN Sanctions Committee amended the ISIL (Da’esh) and Al-Qaida list; independent notices describe amendments to four entries.

2026-08-14

SECO updated the Swiss SESAM database and published the corresponding Swiss sanctions-list update.

2026-08-17

FINMA published its updated sanctions notice drawing attention to the directly applicable Swiss list change.

Suggested considerations

• Compliance teams may wish to obtain the amended UN list and the updated SESAM data, identify the three amended individuals and one amended entity, and map all aliases, dates of birth, nationalities, addresses, registration details and other identifiers into screening systems.
• Firms should consider immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, vendors, payment beneficiaries and relevant historical transactions against the amended data.
• Where a potential match is identified, firms should consider suspending the relevant transaction or relationship pending a documented false-positive assessment and escalating a confirmed or unresolved match to sanctions, legal and MLRO governance channels.
• For a confirmed match, firms should consider applying the asset-freeze restrictions under SR 946.231.08, preventing funds or economic resources from being made available directly or indirectly to or for the benefit of the designated person or entity, and assessing applicable Swiss notification and reporting requirements.
• Firms should retain evidence of the SESAM and screening-data update, screening timestamps, alert dispositions, approvals, transaction holds and any regulatory or law-enforcement communications.
• Control owners may wish to test whether outsourced screening providers, payment filters, correspondent-bank interfaces and crypto blockchain analytics received the update without delay.
• Compliance teams may wish to note the market reading reflected in parallel official-industry notices: the practical expectation is operational list maintenance and prompt rescreening, not merely awareness of the FINMA publication.

What changed

The list entries covered by the Ordinance of 2025-03-21 on Measures Against Persons and Organisations Connected with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) were amended; the available public notices indicate amendments to three individuals and one entity, rather than a new standalone FINMA rule. The amendments became directly applicable in Switzerland through the UN sanctions-list mechanism, and SECO incorporated them into SESAM on 2026-08-14.

Key dates

10 August 2026

- The WBF amended the list of sanctioned persons, companies, and organizations under the South Sudan measures

11 August 2026

- FINMA published the updated sanctions notice and stated that the urgent amendment would be published on the WBF website the same day

11 August 2026, 23:00

- The updated sanctions entry takes effect and becomes enforceable in Switzerland

Suggested considerations

• Re-screen customers, counterparties, beneficial owners, and payment flows against the updated SESAM sanctions data immediately.
• Freeze any assets or economic resources that match the updated South Sudan sanctions list as soon as the entry becomes effective.
• Block prohibited dealings and ensure no funds or economic resources are made available, directly or indirectly, to listed persons or entities.
• Report any affected business relationships to SECO without delay where a match is identified.
• Perform additional clarifications under Art. 6 GwG when sanctions hits or related suspicion indicators arise.

What changed

• - The WBF amended Annex 2 of the Swiss ordinance on measures against the Republic of South Sudan (SR 946.231.169.9), and FINMA relayed that the authoritative Swiss sanctions database SESAM has been...
• The urgent amendment takes effect today at 23:00, meaning firms must treat the revised list as enforceable from that time onward.
• Financial intermediaries must implement the prohibitions contained in the ordinance for the sanctioned parties.
• Financial intermediaries must freeze assets of sanctioned persons, companies, and organizations.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

25 May 2005

- Erlass der Verordnung über Massnahmen gegenüber Sudan (SR 946.231.18), die den rechtlichen Rahmen für schweizerische Sudan-Sanktionen schafft

04 June 2026

- Das WBF beschliesst und veröffentlicht die Änderung des Anhangs 2 der Verordnung über Massnahmen gegenüber Sudan (SR 946.231.18); die aktualisierte Sanktionsliste tritt in Kraft und ist ab diesem Datum anzuwenden

Suggested considerations

• Führen Sie umgehend einen Abgleich aller Kunden-, Konten- und wirtschaftlich Berechtigten-Stammdaten sowie relevanter Transaktionen gegen die aktualisierte Sudan-Sanktionsliste gemäss Anhang 2 der Verordnung SR 946.231.18 durch.
• Identifizieren und dokumentieren Sie alle Treffer (Hits) zu gelisteten Personen, Organisationen oder Einrichtungen und prüfen Sie diese formal (True Hit vs. False Positive) unter Anwendung eines dokumentierten, vier-Augen-prüfenden Verfahrens.
• Frieren Sie Vermögenswerte von bestätigten gelisteten Personen oder Einrichtungen unverzüglich ein, blockieren Sie Transaktionen und verhindern Sie jede direkte oder indirekte Bereitstellung von wirtschaftlichen Ressourcen, in Übereinstimmung mit der Sudan-Verordnung.
• Erstatten Sie umgehend die erforderlichen Meldungen an die zuständigen Bundesstellen (insbesondere SECO bzw. die im Sanktionsrecht vorgesehenen Behörden) sowie – soweit einschlägig – Verdachtsmeldungen an die Meldestelle für Geldwäscherei (MROS).
• Aktualisieren Sie Ihre Sanktions- und AML-Richtlinien, Arbeitsanweisungen und Kontrollpläne, um die neuen Sudan-spezifischen Listungen und Prozesse zur Vermögenssperre und Meldung explizit zu berücksichtigen.

What changed

• - Der Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) wurde durch Entscheid des WBF aktualisiert, was Änderungen an der Sanktionsliste (gelistete natürliche...
• Die aktualisierte Sanktionsliste zu Sudan ist für alle von der Verordnung erfassten Finanzintermediäre unmittelbar verbindlich und ist bei der Prüfung von Kunden, wirtschaftlich Berechtigten,...
• Vermögenswerte von neu gelisteten Personen oder Einrichtungen müssen gemäss Verordnung unverzüglich eingefroren und dürfen weder direkt noch indirekt zur Verfügung gestellt werden.
• Bereits bestehende Geschäftsbeziehungen zu neu gelisteten Personen oder Einrichtungen sind zu suspendieren bzw. abzuwickeln, soweit dies mit den gesetzlichen Vermögenssperren vereinbar ist.
• Institute sind verpflichtet, gefundene Treffer (Treffer bei Konten, Depots, Zahlungs- oder Handelsgeschäften) zu gelisteten Personen oder Einrichtungen den zuständigen Bundesstellen nach den...

Key dates

March 19, 2026

- WBF amends Annex 8 and publishes the update

March 20, 2026, 23:00 Uhr Deadline

- Changes enter into force; sanctions screening and asset handling must reflect delistings immediately thereafter

Suggested considerations

• Screen and release assets: Review client portfolios and frozen assets linked to the 7 delisted persons; release any previously frozen assets unless other sanctions apply (e.g., via GwG AML checks).
• Update internal systems: Refresh sanctions screening tools with the latest SESAM data to avoid erroneous freezes or compliance breaches.
• Report to SECO if applicable: If assets were frozen and are now releasable, notify SECO of prior relationships; conduct GwG Art. 6 due diligence and report suspicions to the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
• Document changes: Maintain audit trails of screening adjustments to demonstrate compliance with ongoing supervisory obligations.

What changed

• - Removal of 7 natural persons from Annex 8, which lists designated individuals subject to asset freezes and other restrictive measures related to the Ukraine situation.
• Update to the SESAM sanctions database (SECO Sanctions Management), Switzerland's authoritative list aligned with EU sanctions.
• No new designations or additional prohibitions introduced; this is a delisting that narrows the scope of sanctions application.

Key dates

March 9, 2026

– WBF published updated sanctions list and modified SESAM database

March 10, 2026, 23:00 UTC

– Effective date for all regulatory changes (enforcement begins)

Immediate Deadline

– Financial intermediaries must implement prohibitions and freeze assets upon effectiveness

Suggested considerations

• *Implement Prohibitions: Execute all transaction bans and restrictions specified in the updated ordinance annexes
• *Asset Freezing: Immediately freeze all assets and funds of sanctioned persons, enterprises, and organizations identified in the updated SESAM database
• *Mandatory Reporting to SECO: Report all affected business relationships to the State Secretariat for Economic Affairs within required timeframes
• *Enhanced Due Diligence: Conduct additional investigations under Article 6 of the Anti-Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious Activity Reporting: If enhanced due diligence cannot eliminate suspicions, file mandatory reports with the Money Laundering Reporting Office (Meldestelle für Geldwäscherei) under Article 9 GwG without delay

What changed

• The regulatory update encompasses four substantive modifications:
• Annex 3: Expansion of the goods list subject to export/import restrictions
• Annexes 12, 13, and 14: Updates to the list of sanctioned persons, enterprises, and organizations subject to asset freezing and transaction prohibitions
• SESAM Database: The Swiss sanctions management database (SECO Sanctions Management) has been updated to reflect all changes, published urgently on the WBF website The changes represent a total...

Key dates

12 December 2025

- Initial adoption of partial 19th package measures, adding 64 persons/organizations to Swiss sanctions list

13 December 2025

- Entry into force of December 2025 sanctions expansions (related prior update)

26 February 2026

- New measures from EU 19th sanctions package enter into force in Switzerland

Suggested considerations

• Implement all prohibitions immediately: Block crypto services to Russian nationals/companies; halt transactions with ruble-pegged stablecoins like A7A5; cease use of banned messaging services for payments.
• Screen and freeze assets of sanctioned persons/entities (~2,600 total); report affected business relationships to SECO.
• Conduct additional due diligence under Art. 6 GwG on suspicions; if unresolved, file immediate suspicious activity report to money laundering reporting office under Art. 9 GwG (SECO report does not exempt this).
• Update sanctions screening tools, client onboarding, and transaction monitoring for new crypto/trade restrictions; review exposures to energy/finance goods listed.

What changed

• - Crypto Restrictions: Complete ban on providing any crypto services to Russian nationals and companies; prohibition on transactions involving specific ruble-backed crypto assets, such as the...
• Payment Systems: Expansion of bans on using certain specialized messaging services for payment traffic.
• Trade/Goods Bans: Expanded list of goods contributing to Russia's military/technological strengthening, including metals for weapon systems, fuel production products, and acyclic hydrocarbons (key...
• Sanctions List Expansion: Builds on December 12, 2025 addition of 64 persons/organizations; Swiss list now aligns fully with EU's, covering ~2,600 targets subject to asset freezes related to Ukraine...
• Related EU 19th package details (adopted by Switzerland) include sanctions on Rosneft/Gazprom Neft, shadow fleet ships, new banks, payment systems like Mir/SPFS, and import bans on LNG/acyclic...

Key dates

February 23, 2026

– SECO publishes Annex 8 amendments on its website

February 24, 2026, 11:00 PM UTC Deadline

– Changes take effect; financial intermediaries must immediately implement all prohibitions

H2 2026

– New organizational obligations under revised Money Laundering Act (GwG) requiring sanctions violation prevention measures take effect

Suggested considerations

• *Implement all prohibitions specified in updated Annex 8 across all business lines and customer relationships
• *Freeze assets of all newly designated natural persons and entities; block transactions with designated entities
• *Report to SECO all affected business relationships within required timeframes, documenting:
• Customer identification and beneficial ownership
• Transaction history with designated parties

What changed

• The February 2026 update to Annex 8 of the Ukraine Sanctions Ordinance introduces modifications to Switzerland's designated persons and entities list related to Russia sanctions.
• 22 natural persons and 42 companies/organizations subject to asset freezes and supply prohibitions
• 116 vessels (primarily tankers in Russia's shadow fleet circumventing oil price caps) subject to purchase, sale, and service prohibitions
• 45 companies in third countries subject to stricter export controls targeting critical goods for Russia's military-industrial complex
• 5 Russian banks and 4 foreign branches subject to transaction prohibitions due to use of Russian payment systems

Key dates

January 29, 2026

– SECO publishes amended Annex 28 of the Sanctions Ordinance

February 1, 2026

– New oil price cap (USD 44.1) becomes effective and binding

Immediate Deadline

– Financial intermediaries must implement updated prohibitions and screening procedures

Suggested considerations

• *Implement price cap enforcement: Update transaction monitoring systems to flag and block crude oil transactions exceeding USD 44.1 per barrel from Russian sources
• *Asset freezing: Continue blocking assets of sanctioned persons and entities; verify no new transactions circumvent the lower threshold
• *Reporting obligations: Report affected business relationships to SECO in accordance with the Sanctions Ordinance
• *Enhanced due diligence: Beyond SECO reporting, conduct additional investigations under Article 6 of the Money Laundering Act (GwG) when suspicious indicators arise
• *Suspicious activity reporting: If enhanced due diligence cannot resolve suspicions, file reports with the Financial Intelligence Unit (FIU) under Article 9 GwG without delay

What changed

• The primary regulatory change is a downward adjustment of the Russian crude oil price cap:
• Previous cap: USD 47.6 per barrel
• New cap: USD 44.1 per barrel
• Effective date: February 1, 2026 This modification targets Russia's shadow fleet and circumvention mechanisms.

Key dates

Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00)

- Prior amendment effective dates, illustrating pattern of rapid implementation

January 13, 2026

- Publication of amendments by WBF, triggering immediate review obligations

November 22, 2026

- Current expiry of ordinance (subject to extension)

Suggested considerations

• Screen clients, transactions, and assets against updated sanctions lists for Russian/Ukrainian designations, focusing on asset freezing (no management/use except administrative actions) and economic resources (no sales, leasing, or financing).
• Block prohibited activities in energy sector, financial services (e.g., derivatives, crypto, guarantees), and related exports/financing; report any frozen assets to authorities.
• Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11).
• Monitor FINMA's sanctions page for full ordinance text and related guidance.

What changed

The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibitions on asset management or use except for normal administrative actions by financial institutions.

Key dates

September 28, 2025

- UN Security Council resolutions automatically reinstated (snapback mechanism triggered)

September 29, 2025

- EU reactivated suspended sanctions on Iran's proliferation activities

October 20, 2025

- Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings

October 21, 2025

- Updated sanctions list effective (23:00 UTC)

December 12, 2025

- Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)

Suggested considerations

• *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

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,...
• Sale or supply of key energy sector equipment
• Gold, precious metals, and diamonds transactions
• Specific maritime equipment
• Designated software exports

Key dates

December 9, 2025, 23:00 UTC

- Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date

Immediate Deadline

- Financial intermediaries required to implement changes according to SR 946.231.18 regulations

Suggested considerations

• *Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
• *System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
• *Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
• *Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
• *Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.

What changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan.

Key dates

18 July 2025

- EU adopts 18th sanctions package against Russia and additional Belarus measures

29 October 2025

- Swiss Federal Council decides to align and amends SR 946.231.116.9

30 October 2025

- New provisions enter into force

13 December 2025

- Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context

Suggested considerations

• 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.g., no transactions with listed banks, no exports of restricted goods).
• 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.g., SWIFT-like messaging for listed banks).
• Review third-party exposures (e.g., Drittländer firms) for evasion risks and document compliance efforts for FINMA audits.

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),...
• Requirements for financial intermediaries to implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
• Reporting to SECO does not exempt intermediaries from AML due diligence under Art. 6 GwG (Anti-Money Laundering Act) or suspicious activity reports under Art.

Key dates

October 29, 2025

- Federal Council decision adopted

October 30, 2025

- Measures effective date

Ongoing Deadline

- Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs)

Suggested considerations

• *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

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 previously limited to RDIF-financed projects Export...
• Chemical components for fuel production

Key dates

21 October 2025, 23:00 Uhr

- Changes enter into force, binding on all Swiss financial intermediaries

29 September 2025

- Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/

20 October 2025

- WBF amends SESAM database and publishes urgent update on its website

12 December 2025

- Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/

Suggested considerations

• Immediate screening: Run full client and transaction screening against updated SESAM list via SECO's website or integrated tools.
• Asset freeze: Block any funds, assets, or economic resources of newly listed parties without delay; report freezes to SECO within specified timelines (typically 30 days).
• Transaction blocks and reporting: Halt prohibited dealings; file suspicious activity reports (SARs) to Money Laundering Reporting Office Switzerland (MROS) if Iran exposure suspected.
• Due diligence enhancement: Review existing Iran-related exposures, especially shadow banking, oil/petroleum networks, or IRGC-linked entities; update risk assessments.
• Internal controls: Ensure automated screening tools are synced with SESAM by effective date; train staff on updates.

What changed

The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication and binding effect under existing ordinances.

Suggested considerations

• Screen and freeze assets: Immediately identify and block assets of newly sanctioned persons/entities per updated annexes; do not release without authorization.
• Report to SECO: Notify SECO of all affected business relationships without delay.
• Conduct AML due diligence: Perform additional clarifications under Art. 6 GwG (Anti-Money Laundering Act) on suspicions; file suspicious activity reports (SARs) with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved—SECO reporting does not substitute this.
• Review transactions: Halt prohibited activities (e.g., payments to/from listed banks, exports of controlled goods, RDIF investments); update screening tools and client onboarding processes.
• Document compliance: Maintain records of screenings, blocks, and reports for FINMA audits.

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 additional Russian banks, and prohibitions on...

Key dates

August 18, 2025

- WBF published updated sanctions notification for Iran (Annex 7 modifications)

August 28, 2025

- Germany, France, and UK triggered UN snapback mechanism

September 15, 2025

- Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)

September 27, 2025

- UN nuclear-related sanctions against Iran automatically reinstated

September 28, 2025

- EU reactivated suspended sanctions related to Iran's proliferation activities

Suggested considerations

• *Immediate compliance obligations:
• *Sanctions List Screening: Update all sanctions screening systems and databases to reflect the August 2025 Annex 7 modifications and subsequent December 2025 total revision
• *Transaction Review: Conduct comprehensive review of existing Iranian counterparties, customers, and beneficiaries against updated FINMA-published lists
• *Account Monitoring: Identify and freeze accounts or assets belonging to designated persons and entities; report frozen assets to authorities
• *Reporting: File mandatory notifications with FINMA and relevant authorities regarding any identified matches or transactions with sanctioned parties

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 significant sanctions escalation: on December 12, 2025, the Swiss Federal Council conducted a total...

Key dates

Immediate upon publication (19 August 2025) Deadline

- Swiss firms must implement updated sanctions list screening and freeze applicable assets/transactions per FINMA/SECO requirements (https://www.finma.ch/en/news/2025/08/20250819-sr-946-231-149-82/)

1 May 2026

- Expiration of UN authorizations/measures on illicit petroleum exports from Libya (Resolution 2769)

15 May 2026

- End of UN Panel of Experts mandate monitoring Libya sanctions

Suggested considerations

• Screen immediately: Run full client, transaction, and asset portfolios against the updated SECO list (SR 946.231.149.82) for matches on newly added/removed designations.
• Freeze assets: Identify and freeze any funds/economic resources of designated parties without delay; report to SECO/FINMA.
• Cease dealings: Halt direct/indirect provision of funds, financial services, or trade facilitation to/from listed parties.
• Update systems: Refresh sanctions screening tools, policies, and training; document compliance evidence.
• Monitor related flows: Heighten scrutiny on Libyan petroleum trade, LIA assets, and arms-related exemptions per UN Resolution 2769.

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 Investment Authority (LIA) frozen cash investments in low-risk deposits, and extensions of related...

Key dates

August 5, 2025

- UN Sanctions Committee decision modifying the Iraq sanctions list

August 13, 2025

- SECO published the updated sanctions notification and SESAM database modifications

Immediate

- Effective date in Switzerland (automatic application upon UN modification)

Suggested considerations

• *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

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 Council sanctions lists enter into force in Switzerland without delay.

Key dates

15 September 2025

- Harmonization of financial sanctions across multiple regimes (including Belarus) enters into force, clarifying fund crediting on blocked accounts and reporting

30 October 2025

- New provisions from Bundesrat decision on 29 October 2025 enter into force, requiring immediate implementation of updated Belarus measures

12 December 2025

- Publication of list expansions by WBF/SECO

13 December 2025

- Expansions to sanctions lists for Russia/Belarus (including 22 persons, 42 entities, 116 ships, 45 trade firms, 5 banks) take effect

Suggested considerations

• Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e.g., Annexes 3, 11a, 19) for freezes and prohibitions; block and report frozen assets/business relationships to SECO immediately.
• Conduct GwG Art. 6 due diligence on suspicions; if unresolved, file AML reports under Art. 9 GwG (SECO reporting does not exempt this).
• Cease prohibited activities: no loans, insurance, deposits >CHF 100k from Belarusians, specialized messaging for payments, or dealings with National Bank of Belarus.
• Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates.
• For trade/energy firms: Halt exports/imports of listed goods (e.g., oil, potash, machinery) and verify third-country counterparties.

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).

Key dates

Immediate upon publication (August 13, 2025)

- Swiss sanctions lists updated; asset freezes and prohibitions take effect instantly for newly designated parties

15 December 2025

- Noted FINMA reference for ongoing list updates and independent freezing measures

31 July 2026

- EU sectoral sanctions against Russia renewed until this date (adopted December 2025), influencing Swiss alignment

Suggested considerations

• Enhance customer due diligence (CDD): Review existing Russia/Ukraine portfolios for matches; implement enhanced monitoring for shadow fleet, oil traders, and FIMI-linked entities.
• Report to FINMA/SECO: Notify of any frozen assets or potential breaches; document compliance efforts to mitigate enforcement risks.
• Update policies: Integrate EU 18th package into internal sanctions frameworks, including red flags for circumvention (e.g., crypto, third-country banks).
• Train staff: Conduct urgent refreshers on secondary sanctions risks per FINMA Risk Monitor 2025.

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 Switzerland via ordinances updated by WBF/SECO.

Key dates

October 17/20, 2025

UNSC Committee adds 2 entries to Sanctions List; Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response

October 18, 2024

UNSC Resolution 2752 adoption; Expands arms embargo scope, basis for national implementations

Immediate/publication date (2025/07/09 per FINMA notice)

Swiss Annex amendment effective; No grace period specified; aligns with "without delay" freezing requirements

July 23, 2025

UK Haiti Sanctions Amendment effective; Parallel indicator of timeline for UN-aligned changes

October 21, 2025

Swiss WBF/VTG announcement; Confirms amended sanctioned list

Suggested considerations

• Screen Immediately: Check client databases, accounts, and transactions against the updated SECO/UN Haiti Sanctions List for new designations; freeze assets/economic resources without prior notice.
• Cease Prohibited Activities: Halt dealings (direct/indirect) with designated parties, including financial services, brokering, technical assistance, or transfers related to military goods/technology.
• Report Findings: Notify SECO/FINMA of matches or frozen assets, providing additional compliance details; maintain records for audits.
• Update Policies/Systems: Revise sanctions screening tools, train staff, and monitor for "connected persons" under updated definitions.
• License Checks: Apply for exemptions only if explicitly available (e.g., humanitarian); no dealings without approval.

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...
• Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing travel bans, asset freezes, and arms...
• Swiss Implementation: FINMA oversees enforcement via SECO's sanction ordinances; updates require alignment with UN lists for asset freezing and prohibitions on dealings with designated parties.

Key dates

26 June 2025

- Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations

15 December 2025

- Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/

Ongoing (continuous) Deadline

- Annex updates published in Federal Gazette; firms must integrate changes without specified delay

Suggested considerations

• Immediate screening: Run updated Annex 2 against client databases, transactions, and assets; block and report any matches to FINMA via SR system.
• Enhanced due diligence: Review Guatemala exposures for links to designated parties (e.g., Public Prosecutor’s Office officials, FCT); suspend dealings and notify self-certification.
• System updates: Ensure sanctions screening tools (e.g., World-Check, Refinitiv) reflect changes; train staff and document compliance.
• Reporting: File suspicious activity reports (SARs) to MROS if pre-existing dealings detected; retain evidence of non-execution of prohibited transactions. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/

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...
• 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's continuously maintained sanctions lists for automated screening.