Switzerland Updates Iran Sanctions List: What Swiss Financial Intermediaries Must Do Now
Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended the list of sanctioned persons, companies, and organisations under the Iran sanctions ordinance on 13 April 2026, with the changes taking effect at 23:00 on 14 April 2026. FINMA published a corresponding notification the same day, reminding financial intermediaries of their binding obligations to screen, freeze, and report. Any firm handling Swiss-regulated accounts, including those using crypto accounting software to track digital asset positions, must treat this update as an immediate compliance trigger.
What Changed and Which Legal Instruments Apply
The amended ordinance and its annexes
The WBF revised Annexes 12 and 14 of the Ordinance of 12 December 2025 on Measures against the Islamic Republic of Iran (SR 946.231.143.6). The ordinance is the primary Swiss legal instrument giving effect to sanctions targeting Iran, and its annexes carry the operative lists of designated individuals and entities. An amendment to those annexes changes who is caught by the prohibitions with immediate legal force.
The SESAM database update
Alongside the ordinance amendment, the WBF updated the SESAM database, which stands for SECO Sanctions Management. SESAM is the authoritative, real-time reference point that Swiss financial intermediaries are expected to screen against. The database was adjusted to reflect the 13 April changes, and the WBF published the update on its official channels. Financial intermediaries that rely on manual list downloads rather than live SESAM feeds should verify they are working from the current version dated no earlier than 13 April 2026.
Obligations for Financial Intermediaries
FINMA's notification is explicit on what is required. Three distinct duties apply in parallel, and none overrides the others.
Implement the prohibitions and freeze assets
Intermediaries must give effect to the sanctions prohibitions set out in the ordinance and freeze any assets belonging to, or controlled by, newly designated persons or entities. Freezing is not discretionary once a match is confirmed. The obligation applies to all asset classes held or administered by the intermediary, which, for firms active in digital assets, means on-chain holdings tracked through digital asset accounting software fall within scope just as conventional fiat positions do.
Report affected business relationships to SECO
Where an intermediary identifies a business relationship affected by the updated designations, it must report that relationship to the State Secretariat for Economic Affairs (SECO). SECO is the Swiss authority responsible for administering economic sanctions and receiving these notifications. Firms should follow SECO's prescribed reporting channel and retain records of the submission.
The SECO report does not discharge the AML duty to MROS
This is the point most likely to be misread in practice. FINMA's notification states clearly that submitting a report to SECO does not release an intermediary from its separate obligations under the Anti-Money Laundering Act (GwG). Specifically:
- If suspicion of money laundering or sanctions evasion remains after the initial SECO report, the intermediary must carry out additional due diligence under Article 6 GwG.
- If that enhanced due diligence fails to dispel the suspicion, the intermediary must file a report with the Money Laundering Reporting Office Switzerland (MROS) without delay, as required by Article 9 GwG.
The two reporting channels serve different legal purposes. SECO receives notifications about frozen assets and affected relationships under sanctions law. MROS receives suspicious activity reports under AML law. An intermediary facing a sanctions hit that also raises money-laundering red flags must use both.
Practical Steps for Compliance Teams
Immediate screening and reconciliation
Compliance teams should run a fresh screen of all client and counterparty records against the updated SESAM database as a priority. Any matches identified need to be escalated through the firm's internal sanctions procedure before the business day closes. For firms managing digital asset positions, this includes reviewing wallet addresses and on-chain counterparty data, not just entity names in the client ledger. Good crypto bookkeeping software should allow for tagging and flagging positions linked to designated entities, but the underlying legal obligation rests with the intermediary, not the tool.
Documenting the dual-reporting assessment
Where a match is found, compliance officers should document their assessment of whether the circumstances also warrant an MROS filing. That assessment should address: the source of the funds, the transaction pattern, and whether any behaviour suggests an attempt to circumvent the freeze. The documentation supports both the AML due diligence obligation under Article 6 GwG and any subsequent regulatory review.
Connecting Swiss sanctions practice to a broader framework
Swiss firms operating across borders will recognise parallels with other jurisdictions. For context on how how OFAC SDN cryptocurrency addresses reshape compliance priorities in the US context, the structural logic of screening, freezing, and reporting is consistent, though the legal instruments and reporting bodies differ. Similarly, FINMA's earlier Hamas and PIJ sanctions update from the same period illustrates how FINMA handles different designation regimes through the same SESAM and SECO framework.
Key Facts at a Glance
The table below summarises the core parameters of this update for quick reference.
| Parameter | Detail |
|---|---|
| Ordinance reference | SR 946.231.143.6, Annexes 12 and 14 |
| Amending authority | WBF (Federal Department of Economic Affairs, Education and Research) |
| List amendment date | 13 April 2026 |
| Entry into force | 14 April 2026, 23:00 |
| Sanctions database | SESAM (SECO Sanctions Management) |
| Asset freeze reporting body | SECO |
| AML suspicion reporting body | MROS (Money Laundering Reporting Office Switzerland) |
| Relevant AML Act provisions | Art. 6 GwG (enhanced due diligence), Art. 9 GwG (suspicious activity report) |
Why This Matters for Firms Using Digital Asset Accounting Tools
Sanctions compliance and financial crime controls are converging with digital asset operations faster than many compliance frameworks anticipated. Firms that use crypto accounting software or digital asset accounting software to track on-chain positions need those systems to surface wallet-level data in a format that feeds directly into sanctions screening workflows. A tool that records transaction history but cannot tag or alert on designated-entity exposure creates a gap between the operational record and the legal obligation. This update is a reminder that the Swiss regulatory perimeter does not treat digital assets differently when it comes to the freeze and report duties under sanctions law.
For firms advising Swiss-regulated clients or operating under FINMA supervision, now is a good moment to review whether your screening cadence matches the pace at which SESAM is updated, and whether your internal escalation procedures clearly separate the SECO notification from the AML reporting assessment.
Source: FINMA
FAQ
SESAM stands for SECO Sanctions Management. It is the official Swiss database maintained by the State Secretariat for Economic Affairs that lists all persons, companies, and organisations subject to Swiss sanctions. Financial intermediaries are required to screen their client and counterparty data against SESAM and to use the current version. The WBF updated SESAM on 13 April 2026 to reflect the latest Iran designation changes.
No. FINMA's notification is explicit that reporting an affected business relationship to SECO under the sanctions ordinance is a separate obligation from the AML duties under the GwG. If a sanctions hit also raises money-laundering suspicion that cannot be resolved through enhanced due diligence under Article 6 GwG, the intermediary must also file a suspicious activity report with MROS under Article 9 GwG. Both reports may be required at the same time.
The WBF amended the list of designated persons, companies, and organisations on 13 April 2026. The changes entered into force on 14 April 2026 at 23:00 Swiss time, in line with FINMA's published notification on the same date.
Yes. The freeze and reporting obligations under the Iran sanctions ordinance apply to all assets held or administered by a Swiss financial intermediary, regardless of asset class. Digital asset holdings, including cryptocurrency positions recorded in crypto accounting or bookkeeping systems, are not exempt. Intermediaries should ensure their digital asset records can be cross-referenced against SESAM-listed entities.
Annexes 12 and 14 of the Ordinance of 12 December 2025 on Measures against the Islamic Republic of Iran (SR 946.231.143.6) were amended. These annexes carry the operative designation lists that define who is subject to the prohibitions and asset-freeze requirements.