Aktualisierte Sanktionsmeldung: Russland
Executive Summary
On 15 June 2026, the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended **Annex 8** of the Swiss Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72) and published the updated sanctions list on its website. The changes, which enter into force the same day at 23:00, require Swiss financial intermediaries to immediately update their sanctions screening, freeze assets of newly listed parties, and report affected relationships to SECO while also fulfilling their anti‑money‑laundering (AML) duties under the Anti‑Money Laundering Act (GwG).
What Changed
- - Annex 8 of the Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72) has been amended by the WBF to update the list of sanctioned persons and entities related to Russia.
- The WBF has published the updated Annex 8 and associated sanctions-list changes on its website, making these changes the operative reference for Swiss sanctions screening and asset-freeze obligations.
- The amended measures enter into force on 15 June 2026 at 23:00, creating an immediate and time‑critical requirement for financial intermediaries to align their controls with the new Annex 8 content.
- Financial intermediaries are instructed to implement all prohibitions arising from the Ordinance, including any new or expanded restrictions connected to the updated Annex 8 listings.
- Financial intermediaries must freeze the assets of persons and entities newly designated or otherwise affected by the Annex 8 amendment and ensure no prohibited transactions or services are carried out for them.
- Financial intermediaries must report any business relationships involving sanctioned persons or entities under Annex 8 to the State Secretariat for Economic Affairs (SECO) in accordance with the reporting requirements of the Ordinance.
Suggested Considerations
- Review the updated Annex 8 of SR 946.231.176.72 as published by the WBF and obtain the latest Swiss sanctions-list data (including from SESAM/SECO where used) before the 23:00 effective time.
- Update internal sanctions screening lists, vendor‑provided screening tools and watchlist filters to incorporate all new and amended entries in Annex 8.
- Run an immediate batch screening of all customers, beneficial owners, controlling persons, counterparties, securities holdings and payment flows against the updated Annex 8 once the changes are operative.
- Identify all existing and pending business relationships that match updated Annex 8 entries and classify them as sanctioned in internal systems.
- Freeze without delay any assets, accounts, securities, or other economic resources belonging to, owned, held or controlled by persons and entities listed in Annex 8, in line with the Ordinance.
- Block any new transactions, services, or dealings that would violate the prohibitions associated with Annex 8 entries, including payments, securities transfers, new account openings, or extensions of credit.
Key Dates
Compliance Impact
The change has a high compliance impact because failure to implement sanctions immediately upon entry into force can constitute a breach of Swiss supervisory law and the Ordinance, potentially leading to criminal sanctions, administrative enforcement by FINMA, and significant reputational damage. Non‑compliance may also trigger AML enforcement exposure where institutions fail to conduct required c
Who is Affected
References
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Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 8 der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.