Wealth & Private Banking in Switzerland

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

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

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

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

13 April 2026

- WBF publishes changes to Annexes 12 and 14 and updates SESAM database.

14 April 2026, 23:00 UTC

- Changes enter into force; asset freezes and prohibitions become mandatory.

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database and Annexes 12/14 immediately.
• Freeze assets of any newly sanctioned or amended persons/entities without delay.
• Report all affected business relationships to SECO promptly.
• Conduct enhanced due diligence under GwG Art. 6 for any suspicion; if unresolved, file a suspicious activity report (SAR) with MROS under GwG Art. 9.
• Monitor FINMA's MyFINMA portal and website for ongoing updates; update internal sanctions screening systems.[User Query]

What changed

• - Amendments to Annexes 12 and 14 of the Ordinance SR 946.231.143.6, updating the list of sanctioned persons, companies, and organizations in the context of Iran sanctions.[User Query]
• Updates propagated to the SESAM database, published on the WBF/SECO website.[User Query]
• Standard requirements reiterated: Implement prohibitions, freeze assets of sanctioned parties, and report affected business relationships to SECO; SECO reporting does not exempt additional GwG Art.

Key dates

19 March 2026

- WBF amends Annex 8, removing 7 natural persons

20 March 2026, 23:00 UTC Deadline

- Changes enter into force; firms must adjust compliance systems accordingly

Suggested considerations

• Screen client databases and transaction records against the updated SESAM database to identify and release any asset freezes or restrictions on the 7 delisted persons, confirming no residual sanctions apply.
• Report any affected business relationships to SECO as per ordinance requirements; conduct additional due diligence under Art. 6 GwG if suspicions remain, and file SARs with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved.
• Update internal sanctions screening tools, policies, and staff training to reflect the SESAM changes; document all reviews for audit trails.
• Monitor FINMA's news and MyFINMA for further updates, as lists are continuously revised.

What changed

• - Amendment to Annex 8 of SR 946.231.176.72 by the Federal Department for Economic Affairs, Education and Research (WBF) on March 19, 2026, removing 7 natural persons from the sanctions list.
• Update to the official Swiss sanctions database SESAM (SECO Sanctions Management), published urgently on SECO's website.
• This delisting narrows the scope of asset freeze obligations under the ordinance, but core prohibitions on transactions, asset blocking, and reporting for remaining listed parties persist.

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

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 12, 2026

- WBF publishes amendment to Annex 2

January 13, 2026, 23:00 UTC Deadline

- Changes enter into force; immediate implementation required

December 12, 2026

- Related EU sanctions extended to this date (Swiss alignment expected)

Suggested considerations

• Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness.
• Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available.
• Report affected business relationships to SECO without delay.
• Conduct GwG Art. 6 due diligence on suspicions; file Art. 9 reports to the Money Laundering Reporting Office if unresolved.
• Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools.

What changed

• - Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions.
• Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website.
• Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art.

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

5 January 2026, 11 a.m. Deadline

Ordinance enters into force; immediate asset freezing and reporting required

4 January 2030

Asset freeze expires after four years, unless extended or revoked

Suggested considerations

• Screen and identify: Immediately review client lists, accounts, and transactions against the ordinance annex listing 37 persons; use FINMA's ordinance publication and Classified Compilation of Federal Law.
• Freeze assets: Block all assets (funds, securities, real estate, etc.) of listed persons; prevent any transfers, payments, or dealings.
• Report to MROS: Notify MROS of frozen assets or relevant knowledge without delay, following FIAA protocols; include details on asset nature, value, and location.
• Internal updates: Update compliance systems, screening tools, and PEP/ sanctions databases; train staff on FIAA obligations.
• Document compliance: Maintain records of screening, freezes, and reports for potential FINMA audits; monitor for updates via FINMA and Federal Council releases.

What changed

• - Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously...
• Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA...
• Duration: The freeze is valid for four years until 4 January 2030, unless revoked earlier.
• Legal basis: Enacted under Article 3 FIAA as a "freeze for mutual legal assistance" post-political change, distinct from but additive to 2018 Venezuela sanctions under the Embargo Act.
• Penalties: Non-compliance with freezing may result in up to three years' custody; reporting violations up to CHF 250,000 fine.

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 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

20 October 2025

- Amendment to the annex published by WBF/EAER

21 October 2025

- FINMA publishes updated sanctions notice and notifies via MyFINMA

21 October 2025, 11:00 pm

- Measures enter into force; immediate blocking and screening obligations apply

Suggested considerations

• Block and report: Freeze any newly or modifiedly sanctioned assets; report to FINMA/SECO via MyFINMA if matches found.
• Update compliance systems: Integrate the annex changes into screening tools, policies, and training; conduct risk assessments for Nicaragua exposure.
• Monitor ongoing: Subscribe to FINMA news (https://www.finma.ch/en/news/) and SECO updates for further deltas.
• Document implementation to demonstrate due diligence in case of FINMA audits.

What changed

• - Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction...
• These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from...
• No broader structural changes to the ordinance itself; this is a targeted annex update, similar to frequent "delta" amendments published by SECO.

Key dates

8 October 2025, 23:00 hours

- Changes enter into force; asset freezes and prohibitions apply immediately thereafter

6 October 2025

- DEFR modifies the sanctions list and updates SESAM database

Suggested considerations

• Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00).
• Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system.
• Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure.
• Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits.

What changed

• - Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance.
• Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance.
• No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations.

Key dates

October 8, 2025, 23:00 Uhr Deadline

- Changes enter into force; immediate implementation required for asset freezes and prohibitions

October 6, 2025

- WBF adjusts SESAM database and publishes changes on its website

October 7, 2025

- FINMA publishes the sanctions notice

Suggested considerations

• Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art. 6.
• Freeze assets of any matched listed persons/entities and prohibit new business.
• Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain.
• Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications.
• Document compliance actions to demonstrate adherence in audits or FINMA inquiries.

What changed

• - Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025.
• Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g.,...
• Prohibition on dealings with listed persons/entities; mandatory asset freeze and reporting obligations under the ordinance and Geldwäschereigesetz (GwG).

Key dates

October 8, 2025 at 23:00

- Changes enter into force; asset freezes and prohibitions apply immediately

October 6, 2025

- WBF publishes update to Annex 7 and SESAM database

Suggested considerations

• Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness.
• Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions.
• Report all impacted business relationships to SECO promptly.
• Conduct GwG due diligence (Art. 6) on any suspicions; file with Money Laundering Reporting Office (Art. 9 GwG) if unresolved.
• Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits.

What changed

• - The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management).
• Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO.
• Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art.

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

18.08.2025

- SECO publishes amendment to Annex 2

19.08.2025

- FINMA issues public notification of the update

20.08.2025

- Amendment enters into force; asset freezes and prohibitions apply immediately

Suggested considerations

• Screen client portfolios, transactions, and relationships against the updated SESAM database and Annex 2 via FINMA's website or MyFINMA portal.
• Freeze assets of newly listed parties without delay; block prohibited transactions.
• Report affected business relationships to SECO promptly; conduct additional GwG Art. 6 due diligence if suspicions arise, and file SARs with the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
• Update internal sanctions screening systems and train staff; document compliance for audit trails.

What changed

• - SECO amended Annex 2 of the Ordinance, likely adding, removing, or modifying listings of sanctioned persons, companies, or organizations related to South Sudan.
• The update requires implementation of prohibitions (e.g., no new business), asset freezing for listed parties, and reporting of affected relationships to SECO.
• Changes stem from ongoing enforcement of UN and EU sanctions, with Switzerland implementing via the Embargo Act; Annexes are dynamically updated.

Suggested considerations

• Screen against updated SESAM database: Immediately query SECO's Sanctions Management system and Annex 2 for new/updated designations; freeze any matching assets and report to SECO/FINMA as required.
• Transaction screening and blocking: Halt any funds transfers, services, or economic resources to/from designated parties; document due diligence.
• Internal compliance update: Review client portfolios, KYC files, and transaction monitoring systems for Sudan exposure; train staff and update policies.
• Reporting obligations: Notify FINMA/SECO of any frozen assets or potential breaches within regulatory timelines (typically 30 days for suspicious activity under AMLA).
• Audit and evidence retention: Maintain records of screening/compliance actions for FINMA inspections.

What changed

• - Amendment to Annex 2 of SR 946.231.18, which lists designated persons, entities, and assets subject to sanctions such as asset freezes and prohibitions on making funds or economic resources...
• Updates reflected in the official Swiss sanctions database SESAM (SECO Sanctions Management), published on the SECO website, ensuring harmonized implementation across Switzerland.
• Urgent (dringliche) amendment entering into force immediately, bypassing standard consultation periods to address time-sensitive developments in the Sudan conflict. Specific details of added/removed...

Key dates

28.06.2023

Original Ordinance effective date; (context for baseline measures)

11.08.2025

Publication of Annex update by WBF

12.08.2025

Measures enter into force; (based on similar recent updates; immediate effect standard)

Immediate (unverzüglich)

Report frozen assets to SECO

Suggested considerations

• Screen Client Base: Immediately rescreen all existing and prospective clients, relationships, and transactions against the updated SECO/FINMA Moldova sanctions list via MyFINMA portal.
• Freeze and Report Assets: Block all funds/economic resources of newly listed parties without delay; report details (e.g., account info, asset values) to SECO promptly.
• AML Due Diligence: Conduct enhanced checks under Art. 6 GwG; if suspicions persist post-SECO report, file suspicious activity report (SAR) with MROS under Art. 9 GwG.
• Internal Controls: Update screening tools, train staff, and document compliance to mitigate enforcement risk from FINMA.
• Monitor Ongoing: Subscribe to FINMA MyFINMA alerts and SECO updates for further Annex changes.

What changed

• - Updated Sanctions List: The WBF amended the Annex to include additional natural or legal persons, organizations, or entities subject to financial sanctions, effective immediately upon publication.
• Financial Sanctions Reinforced: Mandatory asset freezes (sperre von Vermögenswerten), prohibitions on making funds or economic resources available (Bereitstellungsverbote), and reporting requirements...
• No Change to Core Ordinance: The underlying Ordinance from June 28, 2023, is unchanged, but the Annex expansion triggers re-screening of existing relationships.

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...

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.