Russia sanctions now cover more Swiss crypto providers
Since 5 November the acquisition ban applies regardless of the type of crypto service. The ordinance, however, contains exemptions based on nationality and residence permit.
Switzerland has tightened the rules on acquiring ownership of crypto providers. Since 5 November 2026, the relevant provision of the Ukraine ordinance covers companies that provide crypto services, whatever their type. Previously it named services relating to crypto wallets, crypto accounts and custody. FINMA drew attention to the change on 6 November.
The decision comes from the Federal Council, not from the financial market supervisory authority. According to its statement, Switzerland is aligning itself with measures in the EU's 21st sanctions package against Russia and Belarus. The sanctions lists were additionally adjusted by the Federal Department of Economic Affairs, Education and Research (EAER). FINMA requires financial intermediaries to implement the prohibitions and reporting obligations.
Ownership, control and management are regulated
The amendment is set out in Article 20, paragraph 2bis, letter a of the Ukraine ordinance. It prohibits enabling Russian nationals or natural persons resident in Russia to acquire, directly or indirectly, ownership of the companies covered. The legal text names companies founded or registered under Swiss law or under the law of a member state of the European Economic Area.
The other letters also cover direct or indirect control and functions in the management bodies of these companies. The examination therefore goes beyond the question of who signs a purchase contract. According to the wording, indirect ownership and control relationships must also be taken into account. The amendment to letter a was adopted on 4 November and, according to the official footnote, entered into force the following day.
The personal exemptions remain in the law
FINMA's short notice summarises the acquisition ban in brief. Paragraph 3 also matters for concrete application: the prohibitions in paragraphs 1 to 2bis do not apply to Swiss nationals, or to nationals of an EEA member state or of the United Kingdom. Also exempt are natural persons holding a temporary or permanent residence permit from Switzerland, an EEA state or the United Kingdom.
A blanket statement that no Russian person may acquire any stake whatsoever in a Swiss crypto provider would therefore be incomplete. The personal conditions must be examined case by case. However, this exemption in Article 20 does not lift any other applicable sanctions provisions. A person's identity and any listing must continue to be considered separately.
Existing holdings, too, cannot simply be equated with newly enabled acquisition. The current amendment widens the circle of covered services. On its own, it is not evidence that all existing holdings must be confiscated or all customer accounts closed.
SECO and MROS have different tasks
For financial intermediaries, FINMA recalls the freezing of assets belonging to sanctioned persons and the reporting of affected business relationships to the State Secretariat for Economic Affairs (SECO). Obligations under the Anti-Money Laundering Act may apply in addition. The sanctions report does not automatically fulfil this check as well.
If suspicions remain, the supervisory authority requires further clarification under Article 6 of the Anti-Money Laundering Act. If they cannot be dispelled, a report under Article 9 to the Money Laundering Reporting Office (MROS) is required immediately, according to its statement. The two channels serve different purposes: sanctions enforcement on the one hand, suspicion review in the money laundering field on the other.
MROS, which is based at fedpol, analyses incoming suspicious activity reports and supplements them with further information. It then decides case by case whether to refer the matter to the Office of the Attorney General or to a cantonal prosecutor's office. A report is therefore not a conviction and not a publicly established violation.
The new dates have already passed
According to the FINMA statement, the list changes took effect on 4 November at 11 p.m. and the sectoral measures on 5 November. So this is not a change that has only just been announced. For a specific transaction, the ordinance text in force is decisive; SECO expressly refers to the official version on Fedlex for this purpose.
According to SECO, the Federal Council decides in each case whether EU sanctions are adopted in full, in part or not at all. A European decision and its Swiss implementation are therefore separate steps. When a review is under way, companies must take into account both the current list and the relevant prohibitions and exemptions – not merely the publication date of the FINMA notice.
Sources
- FINMA: Sanctions Russia and Belarus, 6 November 2026
- Fedlex: Ukraine ordinance, in particular Article 20, version in force
- SECO: Measures in connection with the situation in Ukraine
- SECO: General information on sanctions
- fedpol: Tasks of the Money Laundering Reporting Office MROS
- Lead image: Yogabrata Chakraborty / Billjones94, Swiss one-franc coins
- Lead image licence: CC BY-SA 4.0
- Article image: Zinneke, Federal Palace Bern
- Article image licence: CC BY-SA 3.0
