Switzerland Updates Myanmar 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 Myanmar sanctions ordinance on 1 June 2026, with the change published on 2 June 2026 and taking effect the same day at 23:00. Every Swiss financial intermediary, including those handling digital assets, must act on this update without delay: freeze the relevant assets, report affected business relationships to SECO, and where suspicion persists, file a separate report with the Money Laundering Reporting Office (MROS).

What Changed and Why It Matters

The amended ordinance

The legal basis is the Ordinance of 17 October 2018 on measures against Myanmar (SR 946.231.157.5). The WBF amended Annex 1 of that ordinance, which contains the designated list of individuals, entities, and organisations subject to Swiss sanctions. The updated list has been reflected in SESAM, the SECO Sanctions Management database that financial intermediaries are expected to screen against.

Effective date and screening urgency

The amendment entered into force on 2 June 2026 at 23:00 Swiss time. From that moment, any financial intermediary that holds or controls assets connected to a newly listed party is in scope. Delays in screening, even of a few hours, can create a compliance gap that regulators treat as a breach of the ordinance.

Obligations on Financial Intermediaries

Three distinct duties under the ordinance

FINMA's notice restates three obligations that flow directly from the ordinance for every in-scope firm:

• Implement the prohibitions. Firms must apply the restrictive measures set out in the ordinance to any newly designated party immediately. This includes transaction prohibitions and the blocking of economic resources.
• Freeze assets. Any assets belonging to, owned by, held by, or controlled by a sanctioned person or entity must be frozen. This covers accounts, securities positions, and digital asset holdings alike.
• Report to SECO. Affected business relationships must be reported to the State Secretariat for Economic Affairs. FINMA is explicit that this SECO notification is mandatory, not discretionary.

The dual-reporting requirement

A point that firms sometimes overlook: reporting to SECO does not discharge the obligation to report to MROS. Under Article 9 of the Swiss Anti-Money Laundering Act (GwG), if a financial intermediary cannot rule out suspicion of money laundering or terrorist financing after carrying out the enhanced due-diligence steps required by Article 6 GwG, it must file a suspicious activity report with MROS immediately. The FINMA notice makes clear that the SECO report and the MROS report are parallel obligations, not alternatives.

Implications for Crypto and Digital Asset Firms

Why digital asset intermediaries face particular screening challenges

Swiss virtual asset service providers, crypto custodians, and trading venues are financial intermediaries under Swiss law and fall squarely within the scope of the Myanmar sanctions ordinance. Unlike traditional bank accounts, digital asset positions can be fragmented across wallets, sub-accounts, and staking protocols, making automated screening against SESAM more operationally demanding. Firms relying on manual processes risk missing a newly listed address or counterparty within the ordinance's effective window.

Where crypto accounting software fits in

Accurate, real-time position data is a prerequisite for any freeze. If a firm's crypto accounting software or digital asset accounting software does not produce a current view of who controls which assets, compliance teams cannot act on a sanctions update the moment it takes effect. The 23:00 effective time on a publication day is not a theoretical edge case; it is precisely the kind of tight window that exposes gaps between a firm's book of record and its sanctions screening workflow. Firms should confirm that their crypto bookkeeping software can export position data on demand and that this feed is connected to their sanctions controls, not siloed from them.

For a broader look at how Swiss intermediaries have been handling similar dual-reporting scenarios, see our analysis of FINMA Hamas and PIJ sanctions obligations for Swiss intermediaries. Firms operating across jurisdictions should also review our piece on OFAC SDN cryptocurrency address compliance priorities, which covers the US dimension of sanctions screening for digital assets.

Practical Steps for Compliance Teams

Immediate actions

• Pull the updated SESAM list and run it against your full client and counterparty database, including digital asset wallet addresses where applicable.
• Identify any matches and freeze the associated assets without waiting for internal escalation cycles to complete.
• Prepare and submit the SECO notification for each affected business relationship.
• Initiate the Article 6 GwG enhanced due-diligence review for each match to determine whether suspicion can be ruled out.
• Where suspicion cannot be ruled out, file with MROS immediately. Do not wait for the SECO process to conclude.

Documentation and audit trail

Swiss supervisory practice expects firms to evidence not just the outcome (freeze, report) but the process: when the screening was run, what version of the list was used, who authorised the freeze, and when the SECO and MROS notifications were submitted. Teams should timestamp each step and retain that documentation in a format that can be produced to FINMA on request.

FAQ

Which legal instrument is being updated?

Annex 1 of the Ordinance of 17 October 2018 on measures against Myanmar, formally cited as SR 946.231.157.5, has been amended. The change was published on 2 June 2026 and entered into force the same day at 23:00.

Does reporting to SECO mean we don't need to report to MROS?

No. The SECO notification and the MROS suspicious activity report are separate obligations. If, after conducting the Article 6 GwG enhanced due-diligence review, you cannot rule out suspicion, you must file with MROS immediately regardless of what you have sent to SECO.

Are crypto custodians and VASPs covered by this ordinance?

Yes. Virtual asset service providers and crypto custodians operating in Switzerland are classified as financial intermediaries under Swiss law and are subject to the Myanmar sanctions ordinance in the same way as banks and securities firms.

Where is the updated sanctions list published?

The amended list is reflected in SESAM, the SECO Sanctions Management database. Financial intermediaries should screen against the current SESAM data, available through the SECO website.

What happens if our screening system missed the update at the 23:00 effective time?

There is no grace period specified in the ordinance. Firms that identify a gap should freeze the relevant assets and submit the required notifications as quickly as possible, then document the timeline in full. Proactive disclosure to FINMA of any delay is generally preferable to waiting for the regulator to identify it during a review.

Source: FINMA