Verordnung vom 7. März 2025 über die Sperrung von Vermögenswerten im Zusammenhang mit Syrien (Anpassung des Anhangs)
Executive Summary
On July 31, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) amended the annex to the Syria Asset Freezing Ordinance (SR 196.127.27), originally enacted March 7, 2025, to update the list of designated individuals subject to comprehensive asset freezes. This amendment reflects Switzerland's ongoing implementation of targeted financial sanctions against politically exposed persons connected to the former Assad regime, requiring immediate compliance from all financial intermediaries and asset holders operating in Swiss jurisdiction.
What Changed
The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices. The amendment operates under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA; SR 196.1), which provides the legal foundation for asset freezes based on suspicion of illicit acquisition rather than active criminal conviction.
What You Need To Do
- *Immediate compliance steps for financial institutions
- *Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
- *Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
- *File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
- *Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities
- *Document compliance measures demonstrating immediate implementation of freezes and reporting to MROS
Key Dates
Compliance Impact
Urgency: CRITICAL
Who is Affected
Summary
No description available.