Switzerland amends Russia sanctions annex

Swiss financial intermediaries must freeze assets and report affected Russia-sanctions relationships to SECO

Change
Switzerland amended Annex 8 of its Ukraine-related Russia sanctions ordinance, with the changes entering into force on February 24, 2026 at 23:00.
Why it matters
The amendment updates Switzerland's operative Russia sanctions list under SR 946.231.176.72. Financial intermediaries must 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 financial intermediaries must update sanctions-screening controls against the amended Annex 8 entries and implement the prohibitions from February 24, 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 additional enquiries under Article 6 AMLA and file with MROS under Article 9 if suspicion cannot be cleared, because SECO reporting does not discharge AML reporting duties.

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