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Aktualisierte Sanktionsmeldung: Sudan

AI Analysis

FINMA has published an updated sanctions notice for **Sudan**, reflecting a change to **Annex 2 of the Swiss Sudan sanctions ordinance (SR 946.231.18)** made by the WBF. For compliance teams, this means the Swiss sanctions universe has changed immediately and firms must ensure screening, blocking, and reporting controls are aligned with the updated Swiss list and effective time.

Key dates

10 August 2026
- The WBF amended Annex 2 of the Sudan sanctions ordinance, according to the related Swiss official notice
11 August 2026
- The updated Sudan sanctions measures enter into force at **23:00**

Suggested considerations

  • Firms must update sanctions screening systems immediately to reflect the amended Sudan Annex 2 list in SESAM.
  • Firms must identify and freeze any assets or economic resources belonging to or controlled by newly listed persons.
  • Firms must block prohibited transactions and services involving sanctioned Sudan-related persons or entities.
  • Firms must review all existing customer, counterparty, and beneficial owner relationships for matches against the updated list.
  • Firms must report affected business relationships to SECO in line with the ordinance.
  • Firms must perform additional AML clarifications under Art. 6 AMLA/GwG where suspicion indicators are present.

What changed

  • - The WBF amended Annex 2 of the ordinance of 25 May 2005 on measures against Sudan (SR 946.231.18).
  • The Swiss authoritative sanctions database SESAM was adjusted to reflect the change.
  • The changes take effect today at 23:00, making the update operationally urgent for Swiss financial intermediaries.
  • Financial intermediaries must implement the prohibitions under the ordinance, including freezing assets of sanctioned persons.
  • Financial intermediaries must report affected business relationships to SECO.
  • Reporting to SECO does not replace the duty to perform additional clarifications under Art. 6 AMLA/GwG when there are suspicion indicators.

Compliance impact

The compliance impact is high because sanctions measures are immediately enforceable and require prompt operational action on screening, freezing, and reporting. Non-compliance can expose firms to supervisory enforcement, remedial orders, and potential sanctions-related or AML-related breaches under Swiss law.

Who is affected

  • Swiss financial intermediaries
  • Banks
  • Wealth managers
  • *private banks with client onboarding, screening, or asset-freezing responsibilities.
  • Asset managers
  • *investment firms dealing with portfolios that may include sanctioned persons or counterparties.
  • Payment providers
  • linked or listed parties.

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

What the FINMA said

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.

Published by FINMA . Read the full notice at the source for the authoritative text.

Relevant Firm Types

BankWealth ManagerAsset Manager
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