Aktualisierte Sanktionsmeldung: Sudan

What Changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan. In July 2025, the EU enacted its fourth sanctions package targeting Sudan, imposing restrictive measures on Alkhaleej Bank (which finances the Rapid Support Forces) and Red Rock Mining Company, as well as military commanders from both the Sudanese Armed Forces and Rapid Support Forces for their roles in ethnic v

Suggested Considerations

• *Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
• *System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
• *Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
• *Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
• *Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.
• *Documentation: Maintain records of screening procedures, dates of implementation, and any remedial actions taken in response to the update.

Key Dates

Who is Affected