FINMA

Swiss Financial Market Supervisory Authority

High Impact

FINMA sanctions update: WBF amends Swiss measures against Hamas and Palestinian Islamic Jihad supporters

Published

Jun 17, 2026

Effective

Jun 16, 2026

Topics

Financial sanctions, Hamas, Palestinian Islamic Jihad, Asset freezing, SECO reporting, Sanctions screening, Anti-money laundering

Executive Summary

FINMA has published a sanctions notice stating that the Federal Department of Economic Affairs, Education and Research amended the annex to the Swiss Ordinance of 10 April 2024 on measures against persons and organisations supporting Hamas or the Palestinian Islamic Jihad (SR 946.231.09). FINMA states that the amendment was made on 15 June 2026, that SECO updated the Swiss SESAM sanctions database and published the update on its website, and that the measures entered into force on 16 June 2026 at 23:00. Financial intermediaries are instructed, in line with the ordinance, to implement the prohibitions, freeze assets of sanctioned persons and report affected business relationships to SECO. FINMA also reminds intermediaries that notifying SECO does not replace separate AML obligations: where suspicions arise, they must conduct additional clarifications under Article 6 AMLA and, if suspicions cannot be dispelled, report immediately to the Money Laundering Reporting Office Switzerland under Article 9 AMLA.

What Changed

modifiedAnnex to Swiss Ordinance SR 946.231.09 amended

The annex reflected the prior list under the ordinance before the WBF amendment.

New

The annex has been amended by the WBF, requiring institutions to use the updated Swiss sanctions reference data.

modifiedSECO SESAM sanctions database updated

Screening systems using SESAM would have contained the previous version of the relevant sanctions entries.

New

Screening and control processes should use the SECO-published SESAM update for this sanctions regime.

newEffective time confirmed

The FINMA notice did not previously provide this implementation time for the amended annex.

New

The amendment is effective from 16 June 2026 at 23:00.

modifiedFinancial intermediary action required

Obligations applied under the ordinance using the prior sanctions annex.

New

The same ordinance obligations must be applied against the amended annex and updated SESAM data.

modifiedAML escalation remains separate from SECO sanctions reporting

Sanctions reporting to SECO and AMLA suspicious activity reporting are separate legal processes.

New

Institutions must continue to assess AML suspicion indicators independently of any SECO sanctions notification.

Business Impact

Who is affected

Directly affected

Swiss financial intermediaries subject to the ordinance, including banks, securities firms, asset managers, trustees, insurers where relevant, payment and transaction-processing institutions, and other firms conducting sanctions screening or holding client assets.

Indirectly affected

group compliance functions, outsourced screening providers, custodians, correspondent banks, client onboarding teams, payment operations, sanctions data vendors and audit/control teams supporting Swiss business.

Jurisdictions

Switzerland

Business processes

Sanctions list ingestion and reference-data governance, Customer, counterparty and beneficial-owner screening, Payment and transaction screening, Asset freeze and blocking controls, SECO notification workflow for affected business relationships, AMLA Article 6 clarification and Article 9 MROS escalation assessment, Evidence retention and management reporting for sanctions implementation

Estimated effort

Medium

Compliance risk

High

Affected Reports

Sanctions screening list update and deployment control for SECO SESAM dataCustomer, counterparty and beneficial-owner rescreening results logAsset freeze / blocked assets register for sanctioned personsSECO notification file for affected business relationshipsAMLA suspicion assessment and MROS escalation decision record

Field	Validation rule
Sanctions reference source	Use the SECO SESAM update published for the amended annex to Ordinance SR 946.231.09.
Sanctions regime / legal basis	Classify matches under the Ordinance of 10 April 2024 on measures against persons and organisations supporting Hamas or the Palestinian Islamic Jihad, SR 946.231.09.
Effective timestamp	Apply the measures from 16 June 2026 at 23:00, as stated in the FINMA notice.
SECO reportable relationship indicator	Flag business relationships affected by sanctioned persons for notification to SECO.
AMLA escalation outcome	Record whether additional clarifications under Article 6 AMLA are required and whether unresolved suspicion triggers an Article 9 AMLA report to MROS.

Recommended Actions

7 suggested next steps· derived from source analysis

1
Confirmed actionStep 1 of 7
update sanctions-screening systems and any manual watchlist controls with the SECO SESAM data published for the amended SR 946.231.09 annex.
2
Confirmed actionStep 2 of 7
rescreen customers, beneficial owners, counterparties and pending or recent transactions exposed to the Swiss sanctions regime and document the results.
3
Confirmed actionStep 3 of 7
freeze assets of any sanctioned persons identified and implement applicable prohibitions under the ordinance.
4
Confirmed actionStep 4 of 7
report affected business relationships to SECO through the firm’s established Swiss sanctions notification channel.
5
Confirmed actionStep 5 of 7
perform separate AMLA Article 6 clarifications where suspicion indicators exist and file with MROS under Article 9 AMLA if suspicion cannot be dispelled.
6
AI generatedStep 6 of 7
obtain evidence from sanctions data vendors or internal technology teams that the 2026-06-17 SESAM update was ingested, tested and deployed.
7
AI generatedStep 7 of 7
brief front-office, payments, onboarding and investigations teams on routing between sanctions freezing/SECO reporting and AMLA/MROS escalation.

Timeline

other

Apr 10, 2024

Swiss ordinance SR 946.231.09 on measures against persons and organisations supporting Hamas or the Palestinian Islamic Jihad was dated 10 April 2024.

other

Jun 15, 2026

The WBF amended the annex to Ordinance SR 946.231.09, according to FINMA.

effective date

Jun 16, 2026

The measures entered into force at 23:00.

publication

Jun 17, 2026

FINMA published the sanctions notice and stated that SECO had updated and published the SESAM sanctions database update on its website.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Regulatory news noticeSwiss Financial Market Supervisory Authority FINMAJun 17, 2026
Aktualisierte Sanktionsmeldung ↗
https://www.finma.ch/en/news/2026/06/20260617-sr-946-231-09
OrdinanceSwiss Confederation / FedlexApr 10, 2024
Verordnung über Massnahmen gegenüber Personen und Organisationen, welche die Hamas oder den Palästinensischen Islamischen Dschihad unterstützen (SR 946.231.09) ↗
https://www.fedlex.admin.ch/eli/cc/2024/249/de
Official sanctions information page / SESAM access pointState Secretariat for Economic Affairs SECODate not specified
Sanctions: Ordinances and sanctions measures ↗
https://www.seco.admin.ch/seco/en/home/Aussenwirtschaftspolitik_Wirtschaftliche_Zusammenarbeit/Wirtschaftsbeziehungen/exportkontrollen-und-sanktionen/sanktionen-embargos.html
Primary legislationSwiss Confederation / FedlexOct 10, 1997
Federal Act on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA) ↗
https://www.fedlex.admin.ch/eli/cc/1998/892_892_892/en

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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