Aktualisierte Sanktionsmeldung: Myanmar
Executive Summary
FINMA has issued an updated sanctions notice confirming that the Federal Department of Economic Affairs, Education and Research (WBF) has amended Annex 1 of the Ordinance of 17 October 2018 on Measures against Myanmar (SR 946.231.157.5), including changes to the list of sanctioned persons, entities and organisations. This triggers an immediate obligation for Swiss financial intermediaries to implement the updated prohibitions, freeze assets of newly listed parties, and report affected relationships to SECO while maintaining parallel AML duties under the Anti-Money Laundering Act (GwG).
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, companies and organisations.
- Financial intermediaries must report business relationships affected by the Myanmar sanctions list changes to SECO in line with the sanctions ordinance.
- The reporting obligation to SECO does not replace or limit the duty to conduct further clarifications under Article 6 of the Anti-Money Laundering Act (GwG) if there are grounds for suspicion.
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.
- File a suspicious activity report with MROS under Article 9 GwG without delay if suspicions identified under Article 6 GwG cannot be dispelled, irrespective of and in addition to any report made to SECO.
Key Dates
Compliance Impact
The update has high sanctions and AML risk implications: failure to freeze assets, implement prohibitions, or meet SECO and MROS reporting duties can expose firms to administrative enforcement by FINMA, criminal liability under sanctions law, and significant reputational damage. Robust, time-sensitive implementation and documentation of controls around the 23:00 go‑live are essential to demonstrat
Who is Affected
References
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Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 1 der Verordnung vom 17. Oktober 2018 über Massnahmen gegenüber Myanmar (SR 946.231.157.5) publiziert.