Aktualisierte Sanktionsmeldung: Sudan
Executive Summary
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has amended Annex 2 of the Ordinance of 25 May 2005 on Measures against Sudan (SR 946.231.18), updating Switzerland's sanctions list in alignment with UN and international developments. This matters for Swiss financial institutions as it imposes immediate asset freeze and reporting obligations on newly designated individuals and entities linked to threats against Sudan's peace and security, including RSF support and mercenary activities. Compliance teams must screen and act swiftly to avoid FINMA enforcement under supervisory law. #
What Changed
- - Amendment to Annex 2 of SR 946.231.18 by WBF, adding seven individuals to the Sudan sanctions list, mirroring recent UN-aligned updates (e.g., UK additions on 5 February 2026 for persons like Alvaro Andres Quijano Becerra and Abu Aqla Mohamed Kaika
- Sanctions include asset freezes, prohibitions on dealings with designated persons' funds or economic resources, and mandatory reporting to authorities, consistent with Switzerland's implementation of UNSC Resolution 1591 via the Embargo Act.
- Updates reflect global coordination, with UNSC Resolution 2791 (2025) extending the Sudan regime to 12 October 2026, emphasizing targeted measures against human rights violations, humanitarian obstructions, and armed group support.
Suggested Considerations
- Immediate screening: Review client databases, transactions, and assets against updated Annex 2 for the seven new designations; freeze any matching funds or resources without delay.
- Reporting: Notify FINMA or relevant authorities (e.g., State Secretariat for Economic Affairs SECO) of any holdings or suspicions; relevant firms must report to OFSI equivalents in Switzerland.
- No dealings: Cease all transactions, payments, or benefits to/from designated persons unless licensed; maintain records for 10+ years per Embargo Act.
- Controls update: Enhance sanctions screening tools, train staff, and audit AML/sanctions programs for Sudan-specific risks like RSF financing or mercenaries.
- Licensing check: Apply for exceptions via SECO if needed for humanitarian or existing obligations.
Key Dates
Compliance Impact
Urgency: High - Immediate asset freeze obligations apply from publication (19 February 2026), with FINMA's enforcement powers (coercive measures under administrative law) risking fines, reputational damage, or license revocation for non-compliance. This escalates amid ongoing Sudan conflict, UN extensions, and multi-jurisdictional alignment, heightening cross-border transaction risks.
Who is Affected
References
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Summary
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.