What Changed
- EAER updated Swiss sanctions lists on 3 November, aligning with the EU's 21st sanctions package.
- Russian nationals and residents are prohibited from acquiring ownership in Swiss crypto service providers.
- Financial intermediaries must freeze assets, report to SECO, and fulfill AMLA Art. 6/9 MROS reporting duties.
The Swiss Federal Department of Economic Affairs, Education and Research (EAER / WBF) expanded and adapted Switzerland’s sanctions lists regarding Russia and Belarus on 3 November. Through this action, Switzerland aligns its national sanctions regime with the measures adopted by the European Union under its 21st sanctions package as well as further EU decisions. The updated sanctions lists took effect on 4 November at 23:00, whereas the corresponding sectoral measures entered into force on 5 November.
In the financial domain, the Federal Council has instituted stricter measures targeted at cryptocurrencies. Under the updated legal framework, Russian nationals and natural persons residing in Russia are barred from acquiring ownership in Swiss entities that offer crypto-related services. This ownership ban applies strictly and comprehensively, regardless of the nature or scope of the crypto service provided by the Swiss enterprise.
Financial intermediaries operating in Switzerland are required to implement these bans promptly in compliance with the rules set out in the applicable ordinance. Specifically, financial intermediaries must freeze all assets belonging to sanctioned individuals and report any affected business relationships directly to the State Secretariat for Economic Affairs (SECO).
Crucially, reporting to SECO does not relieve financial intermediaries of their broader obligations under Swiss anti-money laundering regulations. FINMA emphasizes that where suspicions exist, financial intermediaries must conduct further investigations in accordance with Article 6 of the Anti-Money Laundering Act (AMLA / GwG). If such suspicions cannot be dispelled after investigation, the intermediary must submit a suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) without delay under Article 9 AMLA.
Who May Be Affected
Russian nationals, individuals residing in Russia, Swiss crypto service providers, and Swiss financial intermediaries.
Cross-Border Context
Switzerland's adoption of the EU's 21st sanctions package connects Swiss legal requirements directly with EU sanctions developments and affects Russian individuals and entities across borders.
What to check next
- Review the specific provisions of the relevant Swiss sanctions ordinance published by the Federal Council and EAER.
- Verify reporting templates and procedures issued by SECO and MROS regarding sanctioned asset freezes and suspicious activity reporting.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.