Switzerland amends Ukraine sanctions Annex 8
Swiss financial intermediaries must update Ukraine-sanctions controls after Annex 8 amendment
FINMA
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Change
Switzerland amended Annex 8 of its Ukraine-related sanctions ordinance, with the change entering into force on April 1, 2026 at 23:00.
Why it matters
The amendment changes the operative Swiss sanctions list under SR 946.231.176.72. Swiss financial intermediaries must update SESAM-based screening controls, implement the prohibitions, freeze assets of sanctioned persons and report affected business relationships to SECO, while still completing AML enquiries and MROS reporting where suspicion remains.
Implications
- — Swiss sanctions-screening teams must update customer and transaction-screening controls with the amended Annex 8 entries from April 1, 2026 at 23:00.
- — Swiss financial intermediaries holding assets of sanctioned persons must freeze those assets and report affected business relationships to SECO under the Ordinance.
- — AML compliance teams at Swiss financial intermediaries must continue Article 6 AMLA enquiries and file with MROS under Article 9 AMLA if suspicion cannot be cleared, because SECO reporting does not replace AML reporting duties.
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