Swiss sanctions: what changes for companies on 1 November
Four ordinances now share more uniform financial rules. For banks, exporters and aid organisations, clean case-by-case screening matters most.
The Federal Council is harmonising the financial provisions in four Swiss sanctions ordinances as of 1 November 2026. The regimes affected are those on the Taliban, on ISIL and Al-Qaida, on North Korea and on Iran. The adjustment is not a new, blanket round of sanctions. For banks, exporters, insurers and aid organisations, however, it changes how individual payments are screened in practice.
Four ordinances, more uniform rules
The Federal Council adopted the changes on 25 September. The aim is to harmonise financial provisions and remove ambiguities. Back in 2025, Switzerland had already aligned comparable rules in sanctions ordinances based on European Union measures. Four ordinances whose basis is resolutions of the UN Security Council now follow.
The central message for companies is therefore not "new prohibitions for everyone" but "more precise procedures within existing prohibitions". Anyone who only screens lists of sanctioned persons does not cover the obligations in full. The payment route, the beneficial owners, the purpose and the recipient of a transaction also matter.
Credits to blocked accounts
The revised rules make clear that third parties may transfer funds to blocked accounts provided the amounts remain blocked there. Such a credit does not lift the freeze. It must be reported to the competent authorities.
This is practically relevant for financial institutions. A frozen account must not simply be treated like a closed account. Incoming payments can be permissible while forwarding or paying out remains prohibited. Compliance systems must reflect this distinction and prevent technically authorised bookings from becoming economically available.
Immediate reporting and an annual holdings report
Persons and institutions that hold or manage funds or economic resources of sanctioned actors must report them to the State Secretariat for Economic Affairs. The clarifications also provide for annual reporting by financial institutions: amounts held as of 31 December must be reported by 15 February.
Credits to blocked accounts likewise remain subject to immediate reporting. This creates two levels: event-related reporting when a relevant transaction occurs, and periodic stocktaking. Companies should therefore not bundle responsibilities, deadlines and evidence into a single general sanctions review.
Humanitarian exemptions remain narrowly limited
The ordinances on the Taliban, on ISIL and Al-Qaida and on North Korea receive harmonised definitions of humanitarian exemptions. For Iran, reporting and authorisation exemptions for certain transfers by or for international organisations are set out more precisely. In addition, certain transactions in connection with food, medicines, medical devices, health services, agriculture and humanitarian purposes remain exempt from a specific obligation.
These rules are not a blanket release. A humanitarian purpose does not replace the assessment of whether all conditions are met and whether other prohibitions still apply. Banks and aid organisations in particular must be able to document which provision they rely on and why the specific payment falls under it.
The Iran list will in future run through the SECO system
A further technical change concerns the Iran ordinance. Updates to certain annexes will in future be published via SECO's SESAM system. For companies, it is therefore not enough to keep using a list that was downloaded once. Screening data and internal references must be kept up to date.
This applies especially to companies with international supply chains. It is not only the direct customer that counts. Intermediaries, banks, carriers and beneficial owners can make a transaction relevant under sanctions law. At the same time, an automated name similarity must not be treated as a match without review; otherwise transactions may be blocked unnecessarily.
What companies should check before November
Affected organisations should first compare their internal directives with the new wording. Second, reporting processes for incoming credits and annual holdings must be clearly assigned. Third, humanitarian exemptions belong in documented case-by-case procedures. Fourth, data sources and list screening should point to SECO's current offering.
The clarifications create more uniformity, but they do not relieve companies of the legal assessment. Complex payment and supply chains may require specialist advice. What matters is neither to overstate the change as a new general blockade nor to underestimate it as a purely editorial clean-up.
Sources
Federal Council: Clarification and harmonisation of sanctions provisions
Federal Council: Amending texts for the four ordinances (PDF)
