Sanktionsmeldung: Guinea-Bissau
Executive Summary
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published an amendment to Annex 1 of the Ordinance on Measures against Guinea-Bissau (SR 946.231.138.3) on October 7, 2025, updating the sanctions list maintained in the SESAM database. This change, effective October 8, 2025, requires Swiss financial intermediaries to immediately screen clients, freeze assets of listed individuals, and report to SECO, reinforcing compliance with UN Security Council Resolution 2048 (2012) and EU measures following the 2012 military coup. It matters for preventing sanctions evasion and ensuring adherence to Switzerland's Embargogesetz (EmbG), with non-compliance risking FINMA enforcement. #
What Changed
- Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025. - Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g., changes for six individuals noted in related updates) were implemented. - Prohibition on dealings with listed persons/entities; mandatory asset freeze and reporting obligations under the ordinance and Geldwäschereigesetz (GwG). Reporting to SECO does not exempt further due diligence or suspicious activity reports (SARs) to MROS if risks persist. #
What You Need To Do
- Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art
- Freeze assets of any matched listed persons/entities and prohibit new business
- Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain
- Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications
- Document compliance actions to demonstrate adherence in audits or FINMA inquiries
Key Dates
Compliance Impact
Urgency: High - Immediate asset freeze and reporting are mandatory from October 8, 2025, with violations exposing firms to FINMA fines, reputational damage, or criminal liability under EmbG and GwG. This update underscores ongoing list volatility (e.g., similar 2024 change), demanding robust real-time screening to avoid inadvertent breaches in low-volume Guinea-Bissau exposures.
Who is Affected
Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat eine Änderung des Anhangs 1 der Verordnung vom 1. Juni 2012 über Massnahmen gegenüber Guinea-Bissau (SR 946.231.138.3) publiziert.