New ordinance on the freezing of assets in the context of Venezuela of 5 January 2026
Executive Summary
The Swiss Federal Council adopted a new ordinance (RS 196.127.85) on 5 January 2026, mandating the immediate freezing of all assets in Switzerland belonging to Nicolás Maduro and 36 associated persons, under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA). This precautionary measure prevents asset outflows amid Venezuela's political upheaval, complementing existing sanctions since 2018, and enables future mutual legal assistance for potential restitution to the Venezuelan people. It matters for Swiss financial institutions as it imposes immediate reporting and freezing obligations with severe penalties for non-compliance. #
What Changed
- Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously sanctioned under the Embargo Act. - Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA provisions. - Duration: The freeze is valid for four years until 4 January 2030, unless revoked earlier. - Legal basis: Enacted under Article 3 FIAA as a "freeze for mutual legal assistance" post-political change, distinct from but additive to 2018 Venezuela sanctions under the Embargo Act. - Penalties: Non-compliance with freezing may result in up to three years' c
What You Need To Do
- Screen and identify
- Freeze assets
- Report to MROS
- Internal updates
- Document compliance
- Consult legal
Key Dates
Compliance Impact
Urgency: Critical. This demands immediate action as the freeze took effect on 5 January 2026 at 11 a.m., with custodial penalties up to three years for failures; given today's date (25 January 2026), firms must confirm compliance now to avoid fines up to CHF 250,000 or enforcement. It heightens AML/sanctions risks amid Venezuela's volatility, overlapping with existing Embargo Act measures, and req
Who is Affected
Summary
No description available.