The Swiss Financial Market Supervisory Authority (FINMA) has highlighted amendments published by the Swiss Federal Department of Economic Affairs, Education and Research to Annexes 8 and 25 of Switzerland’s Ordinance on measures in connection with the situation in Ukraine, updating the relevant sanctions lists with effect from 23 April 2025. FINMA reminded financial intermediaries to implement the ordinance’s prohibitions, freeze the assets of sanctioned persons and report affected business relationships to the State Secretariat for Economic Affairs (SECO). The notice also clarifies that notifying SECO does not remove anti-money laundering duties: where there are grounds for suspicion, intermediaries must carry out additional checks under Article 6 of the Swiss Anti-Money Laundering Act and, if concerns cannot be dispelled, promptly file a report with the Money Laundering Reporting Office in line with Article 9.
Swiss Financial Market Supervisory Authority (FINMA) 2025-04-22
Swiss Financial Market Supervisory Authority alerts firms to updated Ukraine sanctions annexes effective 23 April 2025
FINMA updated sanctions lists under Switzerland’s Ordinance on Ukraine, effective 23 April 2025. Financial intermediaries must enforce prohibitions, freeze sanctioned assets, and report to SECO. Reporting to SECO doesn't exempt intermediaries from anti-money laundering obligations, requiring further checks and potential reporting to the Money Laundering Reporting Office.