Reporting & Disclosure 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

2026-08-17

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

2026-08-14

EAER amended Annexes 2 and 14a of the Ukraine Ordinance; one entity was removed from Annex 14a and 610 Annex 2 individual and entity entries were amended.

2026-08-17 Deadline

The amendments and resulting prohibitions, asset-freezing requirements and reporting implications take effect at 23:00 Swiss time; firms should have implemented screening and control changes by this time.

Suggested considerations

• Compliance teams should load the amended Annex 2 and Annex 14a data into sanctions-screening systems and complete identifier, alias, ownership and account-linkage checks before the 17 August 2026 23:00 effective time.
• Firms should compare the pre-amendment and post-amendment lists to distinguish the Annex 14a deletion from the 610 amended Annex 2 entries and should avoid treating an amended record as cleared without validating the current consolidated list.
• Firms should review customers, beneficial owners, counterparties, payment instructions, securities positions, custody assets and correspondent relationships against the amended records, including possible indirect ownership or control links.
• Where a match is confirmed, firms should consider stopping prohibited activity, freezing relevant funds and economic resources, restricting access in accordance with the Ordinance, and reporting the affected business relationship to SECO using the applicable reporting channel and form.
• For suspected sanctions evasion, inconsistent customer information or other money-laundering indicators, compliance teams may wish to document the Article 6 AMLA enhanced clarification and assess whether an immediate Article 9 AMLA report to the Money Laundering Reporting Office is required.
• Firms should document screening-rule changes, alert disposition, freeze decisions, SECO notifications, AMLA escalation decisions and any controlled release following the Annex 14a removal. Any unblocking should be preceded by checks for separate Annex 2 designation, ownership or other sanctions grounds.

What changed

The EAER amended Annex 2 and Annex 14a of SR 946.231.176.72. The official government notice indicates that one entity was removed from Annex 14a and the entries concerning 610 individuals and entities were amended in Annex 2; the publication does not state that all 610 entries are new designations, so firms should obtain and compare the underlying consolidated and delta lists before determining the precise status of each relationship. Financial intermediaries must implement the applicable prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO.

Key dates

10 August 2026

- The WBF amended Annexes 2 and 8 of the Ukraine sanctions ordinance and published the changes on its website

12 August 2026 Deadline

- The amended measures are published by FINMA and become operationally relevant for compliance teams

12 August 2026, 23:00

- The amended sanctions measures enter into force

Suggested considerations

• Firms must immediately screen customers, counterparties, and beneficial owners against the updated Annex 2 and Annex 8 listings and identify any matches.
• Firms must block and freeze any assets or economic resources belonging to sanctioned persons covered by the updated ordinance.
• Firms must report the affected business relationships to SECO in accordance with the ordinance.
• Firms must perform additional fact-finding under Article 6 GwG/AMLA whenever the sanctions hit or surrounding facts create suspicion that cannot be dismissed.
• Firms must submit an immediate suspicious activity report to MROS under Article 9 GwG/AMLA if the suspicion remains unresolved after additional clarifications.

What changed

• - The WBF amended Annex 2 and Annex 8 of the Swiss ordinance on measures connected with the situation in Ukraine, updating the sanctions list and/or restrictions applicable under SR 946.231.176.72.
• The amended measures become effective today at 23:00, meaning firms must be ready to apply the updated prohibitions without delay.
• Financial intermediaries must implement the prohibitions contained in the ordinance, which includes sanctions-related restrictions beyond ordinary asset freezes.
• Financial intermediaries must freeze the assets of sanctioned persons covered by the update.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

10 August 2026

- The WBF amended Annex 2 of the Sudan sanctions ordinance, according to the related Swiss official notice

11 August 2026

- The updated Sudan sanctions measures enter into force at **23:00**

Suggested considerations

• Firms must update sanctions screening systems immediately to reflect the amended Sudan Annex 2 list in SESAM.
• Firms must identify and freeze any assets or economic resources belonging to or controlled by newly listed persons.
• Firms must block prohibited transactions and services involving sanctioned Sudan-related persons or entities.
• Firms must review all existing customer, counterparty, and beneficial owner relationships for matches against the updated list.
• Firms must report affected business relationships to SECO in line with the ordinance.

What changed

• - The WBF amended Annex 2 of the ordinance of 25 May 2005 on measures against Sudan (SR 946.231.18).
• The Swiss authoritative sanctions database SESAM was adjusted to reflect the change.
• The changes take effect today at 23:00, making the update operationally urgent for Swiss financial intermediaries.
• Financial intermediaries must implement the prohibitions under the ordinance, including freezing assets of sanctioned persons.
• Financial intermediaries must report affected business relationships to SECO.

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

16 July 2026

- The competent UN sanctions committee changed the list of sanctioned persons, companies, and organizations for the Democratic Republic of Congo

17 July 2026

- SECO updated the Swiss sanctions database SESAM and published the change for Switzerland

17 July 2026

- The updated sanctions lists became directly applicable in Switzerland without delay

Suggested considerations

• Review sanctions screening results immediately against the updated Congo-related list in SESAM and any internal watchlists to identify matching clients, counterparties, and beneficial owners.
• Freeze assets and block prohibited dealings involving newly designated persons, companies, or organizations as required by the ordinance.
• Report affected business relationships to SECO in line with the sanctions ordinance requirements.
• Perform enhanced internal clarifications under Article 6 GwG/AMLA whenever a sanctions hit or other red flags create suspicion.
• File an immediate suspicious activity report with the Money Laundering Reporting Office under Article 9 GwG/AMLA if doubts cannot be resolved.

What changed

• - The UN sanctions committee amended the list of sanctioned individuals, companies, and organizations relating to the Democratic Republic of Congo on 16 July 2026.
• The change is directly applicable in Switzerland, so firms cannot wait for a separate Swiss implementing act before acting on the updated list.
• SECO updated the Swiss sanctions database SESAM on 17 July 2026 and published the update on its website.
• Financial intermediaries must implement the prohibitions set out in the ordinance, including freezing the assets of sanctioned persons.
• Financial intermediaries must report the affected business relationships to SECO.

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.

Key dates

04 March 2022

– Original Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) enters into force, establishing the framework for Annex 8 sanctions and related financial measures

15 June 2026

– WBF amends Annex 8 of the Ordinance and publishes the changes on its website, updating the list of sanctioned persons and entities

15 June 2026 Deadline

– The amended measures under Annex 8 enter into force at 23:00, from which time financial intermediaries must have implemented the new prohibitions, asset freezes, and reporting processes

Suggested considerations

• Review the updated Annex 8 of SR 946.231.176.72 as published by the WBF and obtain the latest Swiss sanctions-list data (including from SESAM/SECO where used) before the 23:00 effective time.
• Update internal sanctions screening lists, vendor‑provided screening tools and watchlist filters to incorporate all new and amended entries in Annex 8.
• Run an immediate batch screening of all customers, beneficial owners, controlling persons, counterparties, securities holdings and payment flows against the updated Annex 8 once the changes are operative.
• Identify all existing and pending business relationships that match updated Annex 8 entries and classify them as sanctioned in internal systems.
• Freeze without delay any assets, accounts, securities, or other economic resources belonging to, owned, held or controlled by persons and entities listed in Annex 8, in line with the Ordinance.

What changed

• - Annex 8 of the Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72) has been amended by the WBF to update the list of sanctioned persons and...
• The WBF has published the updated Annex 8 and associated sanctions-list changes on its website, making these changes the operative reference for Swiss sanctions screening and asset-freeze obligations.
• The amended measures enter into force on 15 June 2026 at 23:00, creating an immediate and time‑critical requirement for financial intermediaries to align their controls with the new Annex 8 content.
• Financial intermediaries are instructed to implement all prohibitions arising from the Ordinance, including any new or expanded restrictions connected to the updated Annex 8 listings.
• Financial intermediaries must freeze the assets of persons and entities newly designated or otherwise affected by the Annex 8 amendment and ensure no prohibited transactions or services are carried...

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

17 October 2018

- Original Ordinance on Measures against Myanmar (SR 946.231.157.5) enters into force, establishing the sanctions framework and Annex 1

01 June 2026

- WBF amends the list of sanctioned persons, companies and organisations in Annex 1 of the Myanmar sanctions ordinance

02 June 2026

- SECO publishes the updated Myanmar sanctions list and SESAM data on its website

02 June 2026, 23:00

- The Myanmar sanctions list amendment enters into force and becomes binding for Swiss financial intermediaries

Suggested considerations

• Immediately screen all customers, beneficial owners, counterparties, and related parties against the updated Myanmar Annex 1 list using the current SESAM sanctions data as of the 23:00 effective time.
• Freeze without delay any assets, accounts, or other economic resources held or controlled by persons, entities, or organisations newly listed under the Myanmar sanctions ordinance.
• Block any new or existing transactions that would breach the prohibitions of the Myanmar sanctions ordinance in light of the updated Annex 1 list.
• Submit timely reports to SECO on all business relationships and frozen assets related to persons and entities listed in the updated Myanmar sanctions list, in line with the reporting provisions of the ordinance.
• Conduct additional due diligence and clarifications under Article 6 GwG where there are indications or suspicions of money laundering, terrorism financing, or sanctions breaches in connection with Myanmar-related relationships.

What changed

• - Annex 1 of the Ordinance of 17 October 2018 on Measures against Myanmar (SR 946.231.157.5) has been amended by the WBF, changing the list of sanctioned persons, companies and organisations.
• The SECO sanctions database SESAM (SECO Sanctions Management) has been updated to reflect the amended Myanmar sanctions list.
• The amendment to the Myanmar sanctions list and corresponding SESAM data becomes legally effective at 23:00 on the date indicated in the FINMA notice.
• Financial intermediaries are required to implement the prohibitions set out in the Myanmar sanctions ordinance with respect to the updated list, including blocking the assets of all listed persons,...
• Financial intermediaries must report business relationships affected by the Myanmar sanctions list changes to SECO in line with the sanctions ordinance.

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

2022

- FINMA had already proposed introducing an accountability regime to define managers’ roles and responsibilities more clearly

Summer 2023

- An expert report renewed the call for fines, clearer senior-management responsibility, and greater enforcement transparency

Spring 2024

- The Federal Council’s TBTF report again carried forward these reform themes

End of 2024

- The Parliamentary Investigation Commission report recommended strengthening enforcement effectiveness and transparency

Summer 2025

- The Federal Council set parameters for upcoming legislative reforms including these enforcement-related measures

Suggested considerations

• Review governance maps and delegations to ensure each regulated activity, key control, and approval step is assigned to a clearly identified accountable senior manager.
• Document senior-management responsibilities in a manner that would withstand a future accountability-regime review, including decision rights, escalation duties, and oversight obligations.
• Stress-test enforcement readiness by preparing for formal FINMA proceedings that may end in binding rulings, remediation orders, or publication.
• Update incident-response and remediation workflows so that suspected supervisory-law breaches are escalated, investigated, and corrected quickly and with a complete evidence trail.
• Assume greater reputational exposure in enforcement cases and review internal communications, disclosure controls, and media-response protocols accordingly.

What changed

• - FINMA is again advocating a statutory power to impose fines for serious supervisory-law breaches, which it says would strengthen deterrence and enforcement effectiveness.
• FINMA is again calling for a clearer allocation of responsibility among senior management, consistent with an accountability regime or senior managers’ regime.
• FINMA is again seeking the right to inform the public about concluded enforcement proceedings involving serious rule violations, rather than being restricted to anonymous statistics and exceptional...
• FINMA reiterates that it already uses formal enforcement proceedings to clarify facts and restore compliance, with measures concluded by a ruling.
• FINMA states that, under current law, it may generally only publish anonymous enforcement statistics and individual case disclosures only where there is a particular supervisory interest.

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 24, 2026

- UN Sanctions Committee amends Sudan list

February 25, 2026

- SECO updates SESAM database and publishes on its website; changes directly applicable in Switzerland

Immediate (upon publication) Deadline

- Financial intermediaries must freeze assets and report to SECO; no fixed deadline specified, but "unverzüglich" (without delay) for GwG AML reporting if suspicions persist

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM Sudan list via SECO's website or MyFINMA notifications.
• Freeze (block) assets of any matches and implement transaction prohibitions per the ordinance.
• Report affected business relationships to SECO promptly.
• Conduct additional due diligence under Art. 6 GwG for suspicions; if unresolved, file immediate suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG.
• Monitor FINMA's sanctions page for ongoing updates: https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/.

What changed

• - The UN Sanctions Committee for Sudan amended its list of sanctioned natural persons, companies, and organizations on February 24, 2026.
• SECO updated the SESAM (SECO Sanctions Management) database and published the changes on its website on February 25, 2026.
• This triggers direct applicability in Switzerland under the Federal Council's 2016 ordinance for automatic adoption of UN sanctions lists, amending Annex of SR 946.231.18 (Ordinance on Measures...
• Financial intermediaries are required to implement prohibitions, freeze assets, and report affected business relationships to SECO; SECO reporting does not exempt AML suspicions under Art.

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

5 February 2026

- UK adds six individuals to Sudan sanctions list (e.g., SUD0026 to SUD0031), informing Swiss alignment

18 February 2026

- Switzerland publicly notes addition of seven individuals to Sudan list via ACAMS report

19 February 2026 Deadline

- WBF amends Annex 2 of SR 946.231.18, effective immediately for compliance (publication date)

12 March 2026 Deadline

- UN Panel of Experts interim report due on Sudan sanctions implementation

12 October 2026

- UNSC Sudan sanctions regime extension expires unless renewed

Suggested considerations

• Immediate screening: Review client databases, transactions, and assets against updated Annex 2 for the seven new designations; freeze any matching funds or resources without delay.
• Reporting: Notify FINMA or relevant authorities (e.g., State Secretariat for Economic Affairs SECO) of any holdings or suspicions; relevant firms must report to OFSI equivalents in Switzerland.
• No dealings: Cease all transactions, payments, or benefits to/from designated persons unless licensed; maintain records for 10+ years per Embargo Act.
• Controls update: Enhance sanctions screening tools, train staff, and audit AML/sanctions programs for Sudan-specific risks like RSF financing or mercenaries.
• Licensing check: Apply for exceptions via SECO if needed for humanitarian or existing obligations.

What changed

• - Amendment to Annex 2 of SR 946.231.18 by WBF, adding seven individuals to the Sudan sanctions list, mirroring recent UN-aligned updates (e.g., UK additions on 5 February 2026 for persons like...
• Sanctions include asset freezes, prohibitions on dealings with designated persons' funds or economic resources, and mandatory reporting to authorities, consistent with Switzerland's implementation of...
• Updates reflect global coordination, with UNSC Resolution 2791 (2025) extending the Sudan regime to 12 October 2026, emphasizing targeted measures against human rights violations, humanitarian...

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

January 5, 2026

- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons

January 13, 2026

- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)

Immediate Deadline

- Compliance obligations commence upon publication; no grace period for implementation

Suggested considerations

• *Immediate Screening: Conduct comprehensive screening of all client and counterparty databases against the updated Annex 1 designations within 24-48 hours of publication.
• *Asset Identification: Identify and document any assets, accounts, or positions held by or on behalf of newly designated persons/entities.
• *Freeze Implementation: Immediately freeze all identified assets and block all transactions involving designated parties.
• *Notification: Report any blocked assets to SECO as required under Swiss sanctions legislation (typically within 10 business days).
• *Transaction Review: Suspend all pending transactions with Venezuela-related counterparties pending compliance verification.

What changed

• The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela.
• Update their sanctions screening systems with revised designations
• Identify any existing relationships with newly designated or de-designated persons/entities
• Implement immediate asset freezing for any newly added designations
• Cease all transactions with blocked parties unless specifically authorized

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

29 October 2025

- Prior expansion decision (related 18th EU package adoption)

30 October 2025

- Entry into force of October measures (export restrictions, RDIF transaction bans)

13 December 2025 Deadline

- Measures enter into force; immediate implementation required

31 December 2025

- Extension of certain derogations (e.g., Russia investment withdrawals)

Suggested considerations

• Immediate screening: Review client lists, transactions, and assets against updated SECO sanctions lists (published by WBF) for matches to 22 persons, 42 entities, 116 vessels, 45 export-controlled firms, 5+4 banks, and 8 third-country firms.
• Asset freezing: Block and freeze any matching assets/funds; prohibit making available.
• Transaction halts: Cease dealings with listed banks, entities, vessels, or sanctioned goods/services.
• Reporting: Notify SECO of frozen assets, blocked transactions, or existing business relationships immediately; conduct additional due diligence on suspicions per Art. (FINMA guidelines).
• Ongoing monitoring: Update compliance systems for dynamic lists; train staff on shadow fleet risks and third-country evasion.

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.
• Financial transaction bans: Five Russian banks and four branches of Russian banks in third countries banned from transactions, especially those using Russian payment systems; eight third-country...

Key dates

Immediate (as of December 10, 2025) Deadline

- Financial intermediaries must block assets and report to SECO without delay, per automatic application of UN sanctions

December 9, 2025

- UN Sanctions Committee decision amending the Iraq sanctions list

December 10, 2025

- SECO publishes update on its website and updates SESAM database; changes enter into force immediately in Switzerland

Suggested considerations

• Screen against SESAM database: Immediately rescreen client portfolios, transactions, and business relationships against the updated Iraq sanctions list via SECO's SESAM tool (https://www.seco.admin.ch/sesam).
• Asset freeze: Block and freeze any assets, funds, or economic resources belonging to newly sanctioned parties; do not dispose of or make available.
• Report to SECO: Notify SECO of any matches or business relationships via the designated reporting channel within required timelines (typically immediate for freezes).
• Internal review: Update compliance systems, screening tools, and policies; conduct targeted audits for Iraq/Middle East exposure; train staff on implementation.
• Document compliance: Maintain records of screening, freezes, and reports for FINMA audits.

What changed

• - The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and...
• Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
• Financial intermediaries must implement prohibitions, freeze assets of newly listed or adjusted entities, and notify SECO of any impacted business relationships, consistent with prior Iraq sanctions...

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

18 October 2024

- UN Security Council Resolution 2752 adopted, expanding arms embargo (basis for Swiss/UK updates)

20 March 2025

- Canadian amendments add 3 individuals (related context)

Immediate (publication date: 21 October 2025) Deadline

- Swiss firms must check accounts, freeze assets or economic resources of newly listed persons without prior notice, and report to SECO/FINMA without delay

23 July 2025

- UK Haiti Sanctions Amendment Regulations enter force, reflecting similar UN changes

17

20 October 2025; - UNSC renews regime for one year, adds 2 entries to sanctions list (UK/Jersey notices align with Swiss publication)

Suggested considerations

• Screening and Freezing: Immediately review client databases, accounts, and holdings against the updated SECO Haiti sanctions list; freeze funds/economic resources of designated persons/entities without notice or delay; do not deal with or make available such assets indirectly.
• Reporting: Notify SECO (via ams@seco.admin.ch or portal) and FINMA of matches, providing details on frozen assets; report any additional compliance-facilitating information.
• Ongoing Monitoring: Update transaction screening systems for expanded arms embargo prohibitions (e.g., no financial services for military goods/technology to Haiti-connected persons); cease brokering or technical assistance if applicable.
• Licensing Checks: Refrain from activities unless licensed by competent authorities (e.g., SECO for exemptions).
• Documentation: Maintain records of checks and actions for audits; train staff on updated definitions (e.g., "military goods," "connected with Haiti").

What changed

• - Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals,...
• Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial...
• Switzerland implements via SECO's sanction ordinances, with FINMA enforcing for supervised entities; parallels international updates like UN Resolution 2752 (2024) and 2794 (2025), which reintroduce...

Key dates

October 9, 2025

- FINMA Guidance 04/2025 published and takes effect immediately

January 1, 2029

- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted

Suggested considerations

• *Acknowledge the extended timeline: Update internal compliance calendars and risk management frameworks to reflect the January 1, 2029 deadline rather than January 1, 2026.
• *Monitor FinMIA revision: Track ongoing legislative developments regarding the permanent regulatory framework for OTC derivatives to prepare for post-2029 compliance requirements.
• *Assess competitive positioning: Evaluate whether the extended transitional period affects trading strategies, counterparty relationships, or market competitiveness relative to EU and UK peers.

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...
• Regulatory basis: FINMA Guidance 04/2025, issued October 9, 2025, under authority granted by Article 131 paragraph 6 FinMIO The extension does not eliminate the collateral exchange obligation;...

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

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

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

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

Suggested considerations

• *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

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 Assets held by Foreign Politically Exposed Persons (FIAA; SR 196.1), which provides the legal...