Aktualisierte Sanktionsmeldung: Belarus
Executive Summary
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published updates to Annexes 5, 13, 14, and 15 of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland with additional EU sanctions imposed on July 18, 2025, in response to Belarus's involvement in Russia's war against Ukraine. This matters for Swiss financial institutions as it expands asset freezes, reporting obligations, and prohibitions, strengthening sanctions parity with Russia to prevent circumvention and enhance enforcement effectiveness. #
What Changed
The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19). Financial sanctions reinforce asset freezes, prohibitions on providing funds/services to listed parties, reporting duties to SECO, and bans on transactions with Belarus's National Bank, loans, insurance, and deposits over CHF 100,000 from Belarusian entities.
Suggested Considerations
- Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e.g., Annexes 3, 11a, 19) for freezes and prohibitions; block and report frozen assets/business relationships to SECO immediately.
- Conduct GwG Art. 6 due diligence on suspicions; if unresolved, file AML reports under Art. 9 GwG (SECO reporting does not exempt this).
- Cease prohibited activities: no loans, insurance, deposits >CHF 100k from Belarusians, specialized messaging for payments, or dealings with National Bank of Belarus.
- Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates.
- For trade/energy firms: Halt exports/imports of listed goods (e.g., oil, potash, machinery) and verify third-country counterparties.
Key Dates
Compliance Impact
Urgency: High - Immediate effect from 30 October 2025 demands swift asset screening and reporting to avoid GwG/EmbG violations, with heightened FINMA scrutiny amid Russia-Belarus alignment and recent list expansions (e.g., December 2025). Non-compliance risks enforcement, reputational damage, and sanctions evasion facilitation penalties, especially as circumvention via third countries rises.
Who is Affected
References
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Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung der Anhänge 5, 13, 14 und 15 der Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) publiziert.