What Changed
- Adoption by the Federal Council on 18 September 2026 of EU sanction measures from 23 April 2026, effective 19 September 2026.
- Prohibition of transactions in specified crypto assets, digital central bank currencies (including the digital Belarus Ruble), and with Belarus-based crypto service providers and decentralized platforms.
- Mandatory duties for financial intermediaries to freeze assets, report to SECO, and perform required AMLA (GwG) clarifications and MROS filings.
Financial intermediaries, crypto service providers, and entities conducting financial transactions involving Belarus are directly impacted by new sanctions adopted by Switzerland. On 18 September 2026, the Swiss Federal Council enacted further sanction measures against Belarus in response to the country's continued support of Russia in its war against Ukraine. This action follows the sanctioning of two companies on 22 May 2026 by the Federal Department of Economic Affairs, Education and Research (EAER / WBF).
Effective 19 September 2026, the Federal Council adopted the remaining measures previously enacted by the European Union on 23 April 2026. These provisions further align the Swiss sanction regime for Belarus with its existing sanctions against Russia.
Key Financial and Crypto Restrictions
In the financial sector, the revised regulation introduces a prohibition on transactions involving specific crypto assets and digital central bank currencies, explicitly including the digital Belarus Ruble. Additionally, the Federal Council prohibits transactions with crypto service providers and decentralized platforms headquartered in Belarus.
Obligations for Financial Intermediaries
Under the ordinance, Swiss financial intermediaries are required to:
1. Implement the specified transaction bans;
2. Freeze the assets of designated sanctioned persons; and
3. Report affected business relationships to the State Secretariat for Economic Affairs (SECO).
FINMA emphasizes that notifying SECO does not exempt a financial intermediary from its obligations under Swiss anti-money laundering legislation. If suspicious circumstances arise, intermediaries must conduct additional inquiries pursuant to Article 6 of the Anti-Money Laundering Act (AMLA / GwG). If suspicions cannot be dispelled, intermediaries must immediately file a suspicious activity report with the Money Laundering Reporting Office Switzerland (MROS) in accordance with Article 9 AMLA (GwG).
Who May Be Affected
Swiss financial intermediaries, crypto service providers, decentralized platforms located in Belarus, and entities engaged in cross-border transactions involving Belarus.
Cross-Border Context
Switzerland's adoption of measures created by the EU aligns cross-border financial and crypto sanction regimes concerning Belarus and Russia.
What to check next
- Check the specific ordinance text issued by the Federal Council regarding Belarus sanctions.
- Review SECO guidance on asset freeze reporting procedures.
- Verify AMLA (GwG) compliance obligations with MROS under Articles 6 and 9.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.
Prepared automatically with AI assistance from the official sources linked on this page. Translated from German source content. Translations and explanations do not replace the official text.