FINMA/SECO UN Sanctions List Update: ISIL/Al-Qaida Designations April 2026

Switzerland's State Secretariat for Economic Affairs (SECO) amended its ISIL (Da'esh) and Al-Qaida sanctions list on 31 March 2026, one day after the relevant UN Security Council Sanctions Committee adopted the change. The update to Ordinance SR 946.231.08 takes effect immediately, and every Swiss financial intermediary, including those using crypto accounting software to manage digital-asset portfolios, must act without delay.

What Changed and Why It Matters

The UN Committee Decision of 30 March 2026

The competent UN Sanctions Committee adopted its listing change on 30 March 2026. Under Swiss law, UN Security Council resolutions of this kind are directly applicable, meaning SECO is not required to pass separate domestic legislation before the obligations bind financial intermediaries. SECO updated its SESAM (SECO Sanctions Management) database on 31 March 2026 and published the revised list on its official website the same day.

Scope of Ordinance SR 946.231.08

The ordinance, originally dated 21 March 2025, governs measures against individuals, entities and organisations connected with ISIL (Da'esh) and Al-Qaida. It sits within Switzerland's broader autonomous and UN-derived sanctions framework and is administered jointly by SECO and FINMA. Any counterparty appearing on the SESAM list is subject to the prohibitions and asset-freeze requirements described below.

Obligations for Financial Intermediaries

FINMA's communication is explicit: financial intermediaries are not passive recipients of this information. Three distinct obligations arise simultaneously.

Implement the Prohibitions

From 31 March 2026, intermediaries must apply the transaction prohibitions set out in the ordinance. This means blocking any transfer, payment, or service that would benefit a listed person or entity. For firms relying on digital asset accounting software, automated screening of wallet addresses and counterparty identifiers against the updated SESAM list is a practical minimum control.

Freeze Assets

Any assets held on behalf of a newly designated person, company or organisation must be frozen immediately. "Assets" under Swiss sanctions law is interpreted broadly and covers crypto-assets held in custody or managed accounts, not just traditional bank balances. Crypto bookkeeping software that tracks custody positions should be configured to flag affected balances as restricted and to prevent their movement pending regulatory clearance.

Report to SECO and File a GwG Report if Suspicion Persists

Intermediaries must notify SECO of any affected business relationship. Critically, FINMA's notice emphasises that a SECO report does not discharge the intermediary's separate obligations under Swiss anti-money laundering law. Where the intermediary cannot dispel suspicion after carrying out the additional clarifications required by Article 6 of the Anti-Money Laundering Act (GwG), it must file a suspicious-activity report with the Money Laundering Reporting Office Switzerland (MROS) under Article 9 GwG without delay. These two reporting channels are parallel, not sequential.

Practical Steps for Compliance Teams

Screen Against SESAM Immediately

The SESAM database is the authoritative Swiss sanctions list. Compliance teams should confirm that their screening systems pulled the 31 March 2026 update and that any new designations are matched against the full customer and counterparty book, including crypto-asset wallet addresses where applicable. Firms that rely solely on international screening databases without specifically checking SESAM risk a gap, because Swiss-only or UN-derived listings may appear in SESAM before they propagate to commercial data vendors.

Document the Clarification Process Under Article 6 GwG

Article 6 GwG requires intermediaries to clarify the economic background and purpose of a transaction or relationship whenever there are indications of unusual or suspicious circumstances. When a sanctions match is identified, the compliance file should record the clarification steps taken, the evidence reviewed, and the conclusion reached. If the suspicion cannot be resolved, the Article 9 GwG report to MROS must follow promptly. A well-structured digital asset accounting software workflow can automate the creation of these audit trails, reducing the manual burden on compliance staff.

Coordinate Across Business Lines

Banks, securities dealers, fund managers and payment service providers all fall within the intermediary definition. Crypto-native firms authorised as VASPs or operating under a fintech licence are equally bound. Compliance leads should confirm that the update has been communicated to front-office, operations and technology teams, not only to the AML function.

Connection to Broader Swiss and International Sanctions Practice

This update follows the same procedural pattern as earlier Swiss sanctions amendments. The direct applicability of UN Security Council decisions under Swiss law means the compliance clock starts the moment SECO publishes the updated SESAM list, not when internal systems are next refreshed. Firms that have already built screening workflows in response to similar updates, such as those covered in our article on FINMA Hamas and PIJ sanctions obligations for Swiss intermediaries, will find the process familiar, but the designated entities here are distinct and require a separate screening run.

Internationally, the parallel with US practice is instructive. The expectation that crypto-asset addresses are screenable sanctions identifiers is well established. Our coverage of OFAC SDN cryptocurrency address compliance priorities sets out the due-diligence approach that firms increasingly apply across jurisdictions, and the same logic applies to SESAM-listed entities holding or transacting in digital assets.

Record-Keeping and Audit Readiness

What Regulators Will Look For

FINMA supervisory reviews routinely assess whether intermediaries can demonstrate timely list updates, complete screening coverage and documented decision-making where a match was identified and assessed. Firms using crypto accounting software or digital asset accounting software should ensure that system logs capture the date and version of the sanctions list used for each screening run, and that any override or escalation decision is linked to a written rationale.

The combination of a SECO notification, a GwG Article 6 clarification record and, where needed, a MROS filing creates the three-part paper trail that satisfies both FINMA and, in the event of criminal proceedings, the relevant prosecutorial authorities. Missing any one element exposes the firm to regulatory and potentially criminal liability.

Source: FINMA