What Changed
- UN Sanctions Committee amended the list of sanctioned persons, companies, and organisations regarding the Taliban on 29 October 2026.
- SECO updated the SESAM sanctions database on 30 October 2026, making the changes directly applicable in Switzerland.
- Financial intermediaries must freeze assets, report to SECO, and remain compliant with independent obligations under Art. 6 and Art. 9 GwG.
Financial intermediaries in Switzerland face updated compliance mandates following changes to the UN Taliban sanctions list. On 29 October 2026, the competent UN Sanctions Committee amended the list of sanctioned individuals, companies, and organisations in this context. The changes are directly applicable in Switzerland.
In response, the State Secretariat for Economic Affairs (SECO) updated the relevant Swiss sanctions database, SESAM (SECO Sanctions Management), on 30 October 2026 and published the revision on its website.
Under the provisions of the relevant ordinance, financial intermediaries are required to enforce the prohibitions, freeze the assets of designated persons, and report affected business relationships to SECO. Reporting to SECO does not relieve financial intermediaries of their legal duty to conduct further investigations under Art. 6 of the Anti-Money Laundering Act (GwG) if suspicious circumstances exist. If such suspicions cannot be dispelled, intermediaries must immediately submit a report to the Money Laundering Reporting Office Switzerland pursuant to Art. 9 GwG.
Who May Be Affected
Financial intermediaries operating in Switzerland and entities subject to Swiss sanctions compliance and anti-money laundering regulations.
Cross-Border Context
Applies to financial institutions maintaining accounts or executing transactions subject to Swiss federal jurisdiction and UN Taliban sanctions frameworks.
What to check next
- SECO Sanctions Management (SESAM) database updates on SECO's website
- Obligations for suspicious activity reporting under Art. 6 and Art. 9 of the Swiss Anti-Money Laundering Act (GwG)
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.