Aktualisierte Sanktionsmeldung: Ukraine
Executive Summary
This FINMA publication announces updates to the Swiss Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), specifically the removal of 7 natural persons from Annex 8 on March 19, 2026, effective March 20, 2026, 23:00 UTC. It matters for Swiss financial firms as it requires immediate review of sanctions screening processes to lift any prior asset freezes on these delisted individuals while maintaining vigilance against ongoing Ukraine/Russia sanctions risks, ensuring compliance with SECO and FINMA expectations. #
What Changed
- - Amendment to Annex 8 of SR 946.231.176.72 by the Federal Department for Economic Affairs, Education and Research (WBF) on March 19, 2026, removing 7 natural persons from the sanctions list.
- Update to the official Swiss sanctions database SESAM (SECO Sanctions Management), published urgently on SECO's website.
- This delisting narrows the scope of asset freeze obligations under the ordinance, but core prohibitions on transactions, asset blocking, and reporting for remaining listed parties persist.
Suggested Considerations
- Screen client databases and transaction records against the updated SESAM database to identify and release any asset freezes or restrictions on the 7 delisted persons, confirming no residual sanctions apply.
- Report any affected business relationships to SECO as per ordinance requirements; conduct additional due diligence under Art. 6 GwG if suspicions remain, and file SARs with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved.
- Update internal sanctions screening tools, policies, and staff training to reflect the SESAM changes; document all reviews for audit trails.
- Monitor FINMA's news and MyFINMA for further updates, as lists are continuously revised.
Key Dates
Compliance Impact
Urgency: High - Immediate action required post-20 March 2026 to avoid erroneous ongoing freezes (risking client claims) or premature releases (violating sanctions); non-compliance risks fines up to CHF 540,000 or imprisonment, with SECO referrals to prosecutors for severe cases, amid CHF 7.4 billion in frozen assets as of April 2025. This reinforces the need for real-time sanctions monitoring in a
Who is Affected
References
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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.