Aktualisierte Sanktionsmeldung: Syrien
Executive Summary
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) updated Annex 7 of the Ordinance on Measures against Syria (SR 946.231.172.7) on October 6, 2025, modifying the list of sanctioned persons, companies, and organizations, effective October 8, 2025. This change requires Swiss financial intermediaries to immediately implement asset freezes and report affected relationships to SECO, amid broader Swiss alignment with EU and US easing of Syria sanctions earlier in 2025. It matters for compliance as it mandates swift screening updates to avoid violations of ongoing targeted financial sanctions. #
What Changed
- The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management). - Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO. - Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art. 9 GwG if issues persist. These updates follow prior Swiss easing of sector-specific sanctions (e.g., energy, transport, finance) in March 2025 and full economic sanctions lift in June 2025, but targeted asset freezes remain active. #
What You Need To Do
- Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness
- Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions
- Report all impacted business relationships to SECO promptly
- Conduct GwG due diligence (Art
- Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits
Key Dates
Compliance Impact
Urgency: High - Immediate asset freeze and reporting obligations take effect October 8, 2025, with non-compliance risking FINMA enforcement, fines, or criminal liability under sanctions laws. This matters as it occurs against a backdrop of Syria sanctions easing (e.g., Swiss economic sanctions lifted June 20, 2025; EU measures May 27, 2025), heightening risk of oversight on residual targeted lists
Who is Affected
Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 8. Juni 2012 über Massnahmen gegenüber Syrien (SR 946.231.172.7) publiziert.