What does FINMA's "Aktualisierte Sanktionsmeldung: Sudan" change?

- The UN Sanctions Committee for Sudan amended its list of sanctioned natural persons, companies, and organizations on February 24, 2026. - SECO updated the SESAM (SECO Sanctions Management) database and published the changes on its website on February 25, 2026. - This triggers direct applicability in Switzerland under the Federal Council's 2016 ordinance for automatic adoption of UN sanctions lists, amending Annex of SR 946.231.18 (Ordinance on Measures against Sudan). - Financial intermediaries are required to implement prohibitions, freeze assets, and report affected business relationships to SECO; SECO reporting does not exempt AML suspicions under Art. 6 and 9 GwG. Related prior update: On February 18, 2026 (23:00 CET), WBF amended Annex 2, with SESAM updated accordingly.

Financial intermediaries Any Swiss firms with exposure to listed natural persons, companies, or organizations in the updated SESAM list. FINMA notifies via MyFINMA and its website.

What should firms consider doing?

Screen client portfolios, accounts, and transactions against the updated SESAM Sudan list via SECO's website or MyFINMA notifications. Freeze (block) assets of any matches and implement transaction prohibitions per the ordinance. Report affected business relationships to SECO promptly. Conduct additional due diligence under Art. 6 GwG for suspicions; if unresolved, file immediate suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG. Monitor FINMA's sanctions page for ongoing updates: https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/.

🇨🇭 FINMA Regulatory Notice high

Aktualisierte Sanktionsmeldung: Sudan

Published 26 February 2026 | Switzerland

AI Analysis

This FINMA publication announces an update to the Swiss sanctions list for Sudan following changes by the UN Sanctions Committee on February 24, 2026, directly incorporated into Switzerland's SESAM database by SECO on February 25, 2026. It matters because financial intermediaries must immediately freeze assets of newly listed parties and report to SECO, while continuing AML due diligence under the GwG (Anti-Money Laundering Act), to avoid enforcement risks from non-compliance with Embargo Act (EmbG) obligations.

Key dates

February 24, 2026: - UN Sanctions Committee amends Sudan list
February 25, 2026: - SECO updates SESAM database and publishes on its website; changes directly applicable in Switzerland
Immediate (upon publication) Deadline: - Financial intermediaries must freeze assets and report to SECO; no fixed deadline specified, but "unverzüglich" (without delay) for GwG AML reporting if suspicions persist

Suggested considerations

Screen client portfolios, accounts, and transactions against the updated SESAM Sudan list via SECO's website or MyFINMA notifications.
Freeze (block) assets of any matches and implement transaction prohibitions per the ordinance.
Report affected business relationships to SECO promptly.
Conduct additional due diligence under Art. 6 GwG for suspicions; if unresolved, file immediate suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG.
Monitor FINMA's sanctions page for ongoing updates: https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/.

What changed

- The UN Sanctions Committee for Sudan amended its list of sanctioned natural persons, companies, and organizations on February 24, 2026.
SECO updated the SESAM (SECO Sanctions Management) database and published the changes on its website on February 25, 2026.
This triggers direct applicability in Switzerland under the Federal Council's 2016 ordinance for automatic adoption of UN sanctions lists, amending Annex of SR 946.231.18 (Ordinance on Measures against Sudan).
Financial intermediaries are required to implement prohibitions, freeze assets, and report affected business relationships to SECO; SECO reporting does not exempt AML suspicions under Art. 6 and 9 GwG. Related prior update: On February 18, 2026 (23:

Compliance impact

Urgency: High - Changes are directly applicable with no grace period, requiring immediate asset freezes and reporting to mitigate FINMA enforcement risks (e.g., coercive measures under administrative law). Non-compliance exposes firms to supervisory sanctions, reputational damage, and potential criminal liability under EmbG/GwG, especially amid frequent UN list updates (e.g., recent February 18 ch

Who is affected

Financial intermediaries
Any Swiss firms with exposure to listed natural persons, companies, or organizations in the updated SESAM list.
FINMA notifies via MyFINMA and its website.

FINMA's general framework
Prior Sudan update (Feb 19, 2026)
946-231-18/.1
WBF announcement (Feb 25, 2026)
Broader FATF context
risk jurisdictions in Feb 2026 plenary, increasing AML/sanctions scrutiny

References

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 eine Änderung des Anhangs der Verordnung vom 25. Mai 2025 über Massnahmen gegenüber Sudan (SR 946.231.18) publiziert.

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

Sectors

Banking & Credit Investment Management Wealth & Private Banking

Topics

AML / Financial Crime Reporting & Disclosure

Relevant Firm Types

BankAsset ManagerWealth Manager

View Original on FINMA Back to Feed