Aktualisierte Sanktionsmeldung: Ukraine
Executive Summary
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72) on March 19, 2026, removing 7 natural persons from the sanctions list. This update requires financial intermediaries to immediately review and adjust their sanctions screening processes, as it directly impacts asset freeze obligations and reporting under Swiss sanctions regime. #
What Changed
- - Removal of 7 natural persons from Annex 8, which lists designated individuals subject to asset freezes and other restrictive measures related to the Ukraine situation.
- Update to the SESAM sanctions database (SECO Sanctions Management), Switzerland's authoritative list aligned with EU sanctions.
- No new designations or additional prohibitions introduced; this is a delisting that narrows the scope of sanctions application.
Suggested Considerations
- Screen and release assets: Review client portfolios and frozen assets linked to the 7 delisted persons; release any previously frozen assets unless other sanctions apply (e.g., via GwG AML checks).
- Update internal systems: Refresh sanctions screening tools with the latest SESAM data to avoid erroneous freezes or compliance breaches.
- Report to SECO if applicable: If assets were frozen and are now releasable, notify SECO of prior relationships; conduct GwG Art. 6 due diligence and report suspicions to the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
- Document changes: Maintain audit trails of screening adjustments to demonstrate compliance with ongoing supervisory obligations.
Key Dates
Compliance Impact
Urgency: Medium - The delisting reduces sanctions exposure but demands prompt action to unfreeze assets and update controls, as delays could lead to improper asset retention (potential liability) or missed opportunities for clients. Given the effective date was yesterday (March 20, 2026), firms must act today to align with FINMA expectations; non-compliance risks enforcement under administrative l
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.
Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.