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Aktualisierte Sanktionsmeldung: Sudan

AI Analysis

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 Kaikal involved in RSF support, mercenary enlistment, and financial services to armed groups). - 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 arm

What You Need To Do

  • Immediate screening
  • No dealings
  • Controls update
  • Licensing check

Key Dates

5 February 2026 - UK adds six individuals to Sudan sanctions list (e.g., SUD0026 to SUD0031), informing Swiss alignment.
18 February 2026 - Switzerland publicly notes addition of seven individuals to Sudan list via ACAMS report.
19 February 2026 - WBF amends Annex 2 of SR 946.231.18, effective immediately for compliance (publication date). DEADLINE
12 March 2026 - UN Panel of Experts interim report due on Sudan sanctions implementation. DEADLINE
12 October 2026 - UNSC Sudan sanctions regime extension expires unless renewed.

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

Swiss financial institutionsAll firms*Banking & Credit, Investment Management, Wealth & Private Banking, Payments & E-Money, and Crypto & Digital Assets.International firms with Swiss exposure or clients, given alignment with UK, UN, and other regimes.

Summary

Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 รผber Massnahmen gegenรผber Sudan (SR 946.231.18) geรคndert.

Relevant Firm Types

BankAsset ManagerWealth ManagerAll Firms
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