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Swiss Chinese Law Association — Geneva

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Legal Observatory / Finance and Payments

Legal Update Switzerland Rules in force

FINMA Issues Updated Sanctions Notice on ISIL (Da'esh) and Al-Qaida

The UN Sanctions Committee modified the ISIL (Da'esh) and Al-Qaida sanctions list, which was directly incorporated into Switzerland's SESAM database by SECO on 16 October 2026.

What Changed

  • UN Sanctions Committee altered the sanctions list for ISIL (Da'esh) and Al-Qaida on 15 October 2026.
  • SECO updated the SESAM sanctions database and published the changes on 16 October 2026.
  • Financial intermediaries must freeze assets, report to SECO, and maintain independent AMLA (GwG) reporting obligations to MROS.

Financial intermediaries operating in Switzerland must implement updated sanctions concerning ISIL (Da'esh) and Al-Qaida following a decision by the UN Sanctions Committee on 15 October 2026. The amendment is directly applicable in Switzerland. Consequently, the State Secretariat for Economic Affairs (SECO) updated its SESAM sanctions database on 16 October 2026. Financial intermediaries are required to enforce the prohibitions, freeze assets of designated individuals and entities, and report affected business relationships to SECO. Reporting to SECO does not relieve financial intermediaries of their duty to conduct additional inquiries under Article 6 AMLA (GwG) upon suspicion or to report to MROS under Article 9 AMLA.

Who May Be Affected

Financial intermediaries in Switzerland and individuals or entities dealing with listed assets or relationships.

Cross-Border Context

Implements United Nations international sanctions directly within the Swiss legal framework, affecting international asset management and cross-border financial transactions.

What to check next

  • Check the SECO SESAM sanctions database for specific additions and modifications to the ISIL and Al-Qaida lists.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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