Aktualisierte Sanktionsmeldung: Moldau

Why this matters

## PART 1: ANALYSIS **Executive Summary** FINMA has published a sanctions update for Moldova after the WBF amended the annex to the Swiss Moldova sanctions ordinance (SR 946.231.156.5) on 10 August 2026. The new measures take effect on **11 August 2026 at 23:00**, and compliance teams must immediately screen for the newly listed persons, freeze any affected assets, and report impacted business relationships to SECO. [13] This matters because FINMA explicitly reminds financial intermediaries that reporting to SECO does **not** replace the obligation to conduct additional clarifications under **Article 6 AMLA/GwG** and, if suspicions cannot be resolved, to file a **suspicious activity report under Article 9 AMLA/GwG**. [13] **Key Changes** - The WBF amended the annex to the Swiss Moldova sanctions ordinance (**SR 946.231.156.5**) on **10 August 2026**. [13] - The updated sanctions list adds **6 natural persons** to the Moldova sanctions annex. [13] - The measures include the **freezing of assets** belonging to sanctioned persons. [13] - The measures require financial intermediaries to **implement prohibitions** under the ordinance. [13] - Financial intermediaries must **report affected business relationships to SECO**. [13] - FINMA reiterates that SECO notification **does not discharge** the obligation to carry out additional clarifications under **Article 6 GwG/AMLA** where there are suspicion indicators. [13] - If suspicions cannot be resolved, firms must **submit an MROS report under Article 9 GwG/AMLA** without delay. [13] **Affected Parties** - **Swiss financial intermediaries** subject to the Moldova sanctions ordinance, including banks, securities firms, asset managers, and other regulated intermediaries. [13] - **Compliance and sanctions screening teams** responsible for name screening, asset freezes, and escalation. [13] - **AML / financial crime functions** that must decide whether sanctions hits also require Article 6 and Article 9 GwG steps. [13] - **SECO-reporting entities** that maintain business relationships or assets linked to listed persons. [13] **Deadlines & Timeline** - **10 August 2026** - The WBF amended the annex to the Moldova sanctions ordinance and updated the Swiss sanctions database. [13] - **11 August 2026** - The amendments were published on the relevant federal website and the new measures became public. [13] - **11 August 2026 at 23:00** - The sanctions measures entered into force. [13] **Required Actions** - Screen all customers, counterparties, beneficial owners, and related parties against the updated Moldova sanctions list immediately. [13] - Freeze without delay any assets or economic resources identified as belonging to the newly listed persons. [13] - Block any transactions or services that would breach the Moldova sanctions prohibitions. [13] - Report any affected business relationships and frozen assets to SECO in accordance with the ordinance. [13] - Perform additional clarifications under **Article 6 GwG/AMLA** wherever a sanctions hit or related facts create suspicion that must be resolved. [13] - File a report with the Swiss Money Laundering Reporting Office under **Article 9 GwG/AMLA** if suspicions remain unresolved after the required clarifications. [13] - Re-check historical client and transaction files for any exposure to the newly listed persons since the effective time. [13] - Update internal sanctions watchlists, escalation rules, and case-management workflows to reflect the new entries immediately. [13] **Compliance Impact** Non-compliance can result in sanctions breaches, supervisory enforcement exposure, and AML/CFT reporting failures, especially where firms fail to freeze assets or report promptly. The risk is elevated because FINMA makes clear that sanctions reporting and AML reporting are separate obligations that may both apply to the same case. [13] **Related Context** FINMA has previously announced Moldova-related sanctions measures under the same ordinance framework, showing that these updates are part of an ongoing sanctions regime rather than a one-off event. The broader EU and Swiss Moldova sanctions architecture targets persons involved in actions undermining Moldova’s sovereignty and stability, including asset freezes and travel restrictions, and the Swiss approach tracks those measures through the SECO/SESAM framework. [2][4][6][13]

AI-generated classification rationale, not a full analysis. Verify with the original FINMA source before acting. Full disclaimer.