FINMA Russia Sanctions Update: Annex 8 Amendment Effective 16 June 2026

Switzerland's Federal Department of Economic Affairs, Education and Research (EAER/WBF) published amendments to Annex 8 of the Ukraine-related measures ordinance (SR 946.231.176.72) on 15 June 2026, with the changes entering into force at 23:00 on 16 June 2026. FINMA has notified all financial intermediaries of their obligations under the updated ordinance, and the compliance requirements are immediate.

What Changed in Annex 8

Scope of the Amendment

The EAER amended Annex 8 of the Ordinance of 4 March 2022 on measures related to the situation in Ukraine. The annex lists the individuals and entities subject to Swiss sanctions, and the June 2026 revision expands or modifies that list. FINMA's notification does not detail every individual entry added or removed, referring financial intermediaries directly to the updated annex published on the EAER's own channels. Firms should treat any gap in their sanctions screening as a priority gap requiring immediate remediation.

Effective Date and Timing

The measures became binding at 23:00 Swiss time on 16 June 2026. That overnight entry into force is deliberate: it limits any window during which parties with advance knowledge could move assets ahead of the freeze. Intermediaries that were not monitoring the EAER publication in real time need to confirm their screening was updated before the start of business on 17 June 2026.

Obligations for Financial Intermediaries

Asset Freezing

Firms must freeze, without delay, all assets belonging to or controlled by any person or entity listed in the updated Annex 8. This applies across account types and asset classes. For firms using digital asset accounting software or running crypto bookkeeping software, this means on-chain holdings attributed to a listed address must be treated identically to fiat balances: no outflows, no internal transfers that would benefit the sanctioned party, and no fee arrangements that could constitute indirect value transfer.

Reporting to SECO

Once a match is identified and assets are frozen, the intermediary must report the affected business relationship to the State Secretariat for Economic Affairs (SECO). This is the primary sanctions reporting channel under the ordinance. The report should cover the identity of the counterparty, the nature and value of the frozen assets, and any known beneficial ownership structure.

Separate MROS Obligation When Suspicion Persists

FINMA is explicit on a point that some firms misread: filing with SECO does not discharge the anti-money laundering obligations that run in parallel. If, after conducting the enhanced due diligence required under Article 6 of the Anti-Money Laundering Act (AMLA), a firm cannot rule out money laundering or terrorist financing, it must file a separate suspicious activity report with the Money Laundering Reporting Office Switzerland (MROS) under Article 9 AMLA. The two reporting channels address different legal duties and neither substitutes for the other.

AML Act Articles 6 and 9: What They Require

Article 6: Enhanced Clarification Duty

Article 6 AMLA requires intermediaries to clarify the economic background and purpose of any transaction or relationship that shows unusual features or where the circumstances give rise to a suspicion. In a sanctions context, a name match alone may not resolve every question: the firm must also consider whether the relationship involves shell structures, atypical transaction patterns, or jurisdictional exposure that cannot be adequately explained. The clarification must be documented.

Article 9: Duty to Report Suspicion to MROS

Where the Article 6 clarification process fails to eliminate the suspicion, reporting to MROS becomes mandatory, not discretionary. During the reporting period the intermediary must also suspend any transaction that could harm the reporting outcome. Crypto accounting software that logs transaction-level detail is directly relevant here: a clean, timestamped audit trail of the clarification steps taken, and any transactions suspended pending the MROS report, will be essential in any subsequent supervisory review.

Practical Steps for Swiss Firms

Screening and Reconciliation

Firms should run an immediate re-screen of their full client and counterparty population against the updated Annex 8 list. For digital asset businesses, that screen should cover both legal-entity names and known wallet addresses. Any crypto bookkeeping software or digital asset accounting software in use must be configured to flag and quarantine holdings associated with a match before any further processing occurs.

Documentation Trail

Every step taken between identifying a potential match and completing the SECO report or MROS filing must be recorded. FINMA supervisory reviews routinely examine whether the timeline from match to freeze was defensible. Firms that rely on manual processes are at greater risk of gaps in that trail, and the regulatory cost of a gap in a sanctions context is significant.

Internal Escalation

Compliance officers should brief relationship managers and operations teams on the dual-reporting obligation before the next business day. The distinction between the SECO report (mandatory on any match) and the MROS report (mandatory when suspicion survives due diligence) is one that front-office staff frequently conflate, and that conflation has consequences.

Broader Context

This update sits within a pattern of accelerating sanctions activity across Swiss and European regulators. FINMA has issued several sanctions notifications in 2026 alone, covering different ordinances and designated parties. Swiss financial intermediaries operating in digital assets face layered obligations: the sanctions ordinance, AMLA, and the FINMA Anti-Money Laundering Ordinance all interact, and a gap in any one layer can create exposure across the others. Firms reviewing their crypto compliance reporting frameworks should treat each FINMA sanctions notification as a prompt to test whether their end-to-end process, from screening through to filing, is functioning as designed.

For context on how Swiss intermediaries handled a comparable dual-reporting obligation earlier in 2026, see our earlier coverage of FINMA Hamas and PIJ sanctions obligations for Swiss intermediaries. Firms managing cross-border exposure may also find the discussion of OFAC SDN cryptocurrency addresses and compliance priorities relevant, given the overlap between US and Swiss designated-party lists in the Russia context.

Source: FINMA