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

Key dates

2026-08-14

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

2026-08-17

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

2026-08-19

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

Suggested considerations

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

What changed

The UN sanctions committee changed the list of sanctioned individuals, companies and organisations covered by SR 946.231.08. Switzerland applies the change directly, without a separate Swiss legislative or regulatory adoption step. SECO updated SESAM, the SECO Sanctions Management database described as authoritative for Switzerland, on 17 August 2026 and published the amendment on its website. The available FINMA notice does not identify in its text which persons or entities were added, removed or amended; firms should therefore obtain the current SESAM data and the associated SECO list-change file rather than rely on the notice alone. Independent sanctions commentary characterises the development as an operational Swiss sanctions-list update requiring implementation through sanctions scre

Who is affected

• Swiss banks and securities firms subject to Swiss sanctions law
• Swiss-authorised asset managers, portfolio managers and trustees
• Swiss payment and financial-services providers handling transactions or assets in Switzerland
• Swiss crypto-asset service providers and other persons that conduct business subject to Swiss sanctions prohibitions

Related regulations

• Ordinance of 21 March 2025 on measures against persons and organisations associated with ISIL (Da’esh) and Al-Qaida (SR 946.231.08)
• Federal Act on the Implementation of International Sanctions (Embargo Act, SR 946.231)
• Ordinance on the Automatic Application of United Nations Sanctions Lists