Switzerland amends its Hamas and Palestinian Islamic Jihad sanctions annex, requiring intermediaries to freeze newly listed parties
Swiss financial intermediaries must freeze the newly listed Hamas/PIJ-regime parties and report affected relationships to SECO, in force from 16 June 23:00
Change
On 15 June 2026 Switzerland's WBF amended the Annex to the ordinance on measures against persons and organisations supporting Hamas or Palestinian Islamic Jihad (SR 946.231.09) and updated the SESAM database; the measures entered into force on 16 June 2026 at 23:00, requiring financial intermediaries to freeze the listed parties' assets and report affected business relationships to SECO.
Why it matters
The WBF amended the Annex to the Swiss ordinance targeting supporters of Hamas and Palestinian Islamic Jihad and updated the SESAM (SECO Sanctions Management) database, with the measures effective 16 June 2026 at 23:00. Financial intermediaries must implement the prohibitions, freeze the listed parties' assets and report affected business relationships to SECO. Reporting to SECO does not discharge their separate AMLA obligations — additional clarifications under Article 6 where suspicion arises, and an immediate MROS report under Article 9 where suspicion cannot be dispelled. The specific designations are published in the updated SESAM database and on the WBF/SECO website.
Implications
- — Swiss financial intermediaries must re-screen their client and counterparty base against the amended Annex to SR 946.231.09 (reflected in the updated SESAM database), implement the prohibitions and freeze the assets of the newly listed persons and organisations, with the measures in force from 23:00 on 16 June 2026.
- — Swiss financial intermediaries must report the affected business relationships to SECO, while recognising that this reporting does not discharge their separate AMLA obligations — additional clarifications under Article 6 where suspicion arises, and an immediate MROS report under Article 9 where such suspicion cannot be dispelled.
- — Sanctions-screening and compliance teams should obtain the specific added or removed designations from the updated SESAM database and the WBF/SECO publication, as the notice confirms the list changed without enumerating the entries.
Who is affected
- — Swiss financial intermediaries implementing the asset freeze and prohibitions under SR 946.231.09
- — Sanctions-screening and compliance teams updating screening against the amended Annex and SESAM
- — AML compliance and MROS-reporting functions handling Article 6 clarifications and Article 9 reports