Aktualisierte Sanktionsmeldung: ISIL (Da'esh) und Al-Kaida

Key dates

2026-08-13

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

2026-08-14

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

2026-08-17

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

Suggested considerations

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

What changed

The list entries covered by the Ordinance of 2025-03-21 on Measures Against Persons and Organisations Connected with ISIL (Da’esh) and Al-Qaida (SR 946.231.08) were amended; the available public notices indicate amendments to three individuals and one entity, rather than a new standalone FINMA rule. The amendments became directly applicable in Switzerland through the UN sanctions-list mechanism, and SECO incorporated them into SESAM on 2026-08-14. The underlying UN regime includes an asset freeze, travel ban and arms embargo under paragraph 1 of UN Security Council Resolution 2734 (2024); firms should assess the amended identifiers and associated aliases and not assume that an unchanged name means unchanged screening risk.

Who is affected

• FINMA-supervised banks and securities firms in Switzerland
• Swiss asset managers, portfolio managers and trustees subject to Swiss sanctions obligations
• Swiss payment and financial-intermediary businesses processing customers, counterparties or payments
• Swiss crypto and digital-asset service providers within the scope of applicable sanctions and AML obligations

Related regulations

• Ordinance of 21 March 2025 on Measures Against Persons and Organisations Connected with ISIL (Da’esh) and Al-Qaida (SR 946.231.08)
• Federal Council Ordinance of 4 March 2016 on the Automatic Application of International Sanctions Lists
• UN Security Council Resolution 2734 (2024)