WBF amends Annex 2 of the Sudan sanctions ordinance, requiring Swiss financial intermediaries to freeze listed assets
Swiss financial intermediaries must implement the amended Sudan prohibitions, freeze the assets of the persons listed in the updated Annex 2 and report affected business relationships to SECO, with effect from 5 June 2026.
Change
On 4 June 2026, Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 2 of the Sudan sanctions ordinance (SR 946.231.18) and updated the SESAM sanctions database; the changes enter into force on 5 June 2026 at 23:00 and require financial intermediaries to freeze the assets of listed persons and report affected relationships to SECO.
Why it matters
The amendment changes the Swiss Sudan sanctions list, requiring financial intermediaries to apply the updated Annex 2 entries and place matched counterparties' assets under freeze under Swiss law. Filing the SECO notification does not discharge the separate anti-money-laundering duties: where suspicions remain after clarifications under Article 6 GwG, intermediaries must report to the Money Laundering Reporting Office under Article 9 GwG. The freeze extends to assets held by parties owned or controlled by listed persons.
Implications
- — Financial-intermediary compliance teams must update sanctions screening against the amended Annex 2 and freeze the assets of any counterparty matching a listed person — applying ownership and control checks to capture entities owned or controlled by listed parties — with effect from the 5 June 2026 entry into force.
- — Financial-intermediary AML/KYC teams must report affected business relationships to SECO and, where clarifications under Article 6 GwG leave suspicions unresolved, file a report with the Money Laundering Reporting Office under Article 9 GwG — the SECO notification does not remove this duty.
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