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FINMA

FINMA

Swiss Financial Market Supervisory Authority

High Impact

FINMA notice: Swiss Iran sanctions annexes and SESAM list updated, effective 18 August 2026 at 23:00

Published

Aug 18, 2026

Topics

Sanctions, Iran, SECO SESAM, Asset freezing, AML reporting, Financial intermediaries

Executive Summary

FINMA has notified financial intermediaries of an update to Switzerland’s sanctions regime against the Islamic Republic of Iran. The Federal Department of Economic Affairs, Education and Research (EAER/WBF) published changes to Annexes 12, 13 and 14 of the Ordinance of 12 December 2025 on measures against Iran (SR 946.231.143.6). SECO’s legally authoritative sanctions database, SESAM, was amended on 17 August 2026, published on SECO’s website, and the amendment enters into force on 18 August 2026 at 23:00 Swiss time. The notice does not provide the listed names in the FINMA text; firms must therefore rely on the updated SECO/SESAM data and the ordinance annexes for screening content. Financial intermediaries are requested, in accordance with the ordinance, to implement the prohibitions, freeze assets of sanctioned persons, companies and organisations, and report affected business relationships to SECO. FINMA also reminds firms that a SECO sanctions notification does not replace AML duties: where suspicion remains after additional clarifications under AMLA Article 6, a report to MROS under AMLA Article 9 remains required.

What Changed

modifiedIran sanctions annexes amended

Previous

Prior versions of Annexes 12, 13 and 14 applied before the WBF amendment published through the 17/18 August 2026 sanctions update.

New

Updated Annexes 12, 13 and 14 apply from the effective time stated in the FINMA notice.

modifiedSECO SESAM sanctions data updated

Previous

Screening and controls based on the prior SESAM Iran sanctions data set.

New

Screening and controls must use the amended SECO SESAM data for the Iran sanctions programme.

newEffective time for this update

Previous

The new WBF/SECO update was not yet in force before the stated entry-into-force time.

New

The amendment is in force from 18 August 2026 at 23:00 Swiss time.

modifiedSanctions implementation duties triggered

Previous

Existing sanctions controls applied to previously listed parties and restrictions.

New

Controls must cover the amended listings and restrictions reflected in Annexes 12, 13 and 14 and SESAM.

modifiedSECO reporting does not replace AMLA escalation

Previous

A sanctions notification to SECO may be a separate operational reporting step.

New

Firms must also preserve AML escalation and MROS reporting where suspicious circumstances remain.

Business Impact

Who is affected

Directly affected

Swiss financial intermediaries that must implement the Iran sanctions ordinance, including firms with customer, payment, custody, trade-finance, securities, insurance, asset-management or fiduciary exposure.

Indirectly affected

sanctions-screening data vendors, core banking and payments technology providers, Swiss or group compliance teams relying on Swiss sanctions controls, and clients or counterparties subject to rescreening or asset-freeze action.

Jurisdictions

Switzerland, Cross-border activity involving Iran-related sanctions exposure

Business processes

Sanctions list ingestion from SECO SESAM, Customer, counterparty and beneficial-owner screening, Payment, securities, custody and trade-finance screening, Asset-freeze and account-blocking controls, SECO notification of affected business relationships, AMLA Article 6 enhanced clarification and Article 9 MROS escalation decisioning

Estimated effort

Medium

Compliance risk

High

Affected Reports

Sanctions screening/watchlist update control for SECO SESAM Iran dataCustomer, counterparty and beneficial-owner rescreening and match-disposition logAsset-freeze or blocking register for sanctioned persons, companies and organisationsSECO notification file for affected business relationshipsAMLA Article 6 clarification and Article 9 MROS reporting decision record
FieldValidation rule
Sanctions list source/versionUse the amended SECO SESAM data for the Iran sanctions programme; FINMA identifies SESAM as the sanctions database authoritative for Switzerland.
Legal basis / sanctions programme referenceReference the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran, SR 946.231.143.6, and amended Annexes 12, 13 and 14.
Effective timestampApply the update from 18 August 2026 at 23:00 Swiss time, as stated in the FINMA notice.
Sanctions notification recipientAffected business relationships identified under the ordinance must be reported to SECO.
AML escalation statusA SECO sanctions notification does not close AML obligations; where suspicion remains after AMLA Article 6 clarifications, an AMLA Article 9 report to MROS is required.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 7

    immediately refresh sanctions-screening data from SECO SESAM and record the version, source, load time and effective timestamp used for production controls.

  2. 2
    AI generatedStep 2 of 7

    run targeted rescreening of customers, beneficial owners, counterparties, payments, custody holdings and open trade-finance cases against the amended Iran sanctions data.

  3. 3
    AI generatedStep 3 of 7

    triage potential matches under the firm’s sanctions escalation procedure, freeze relevant assets where required, and prevent prohibited transactions from proceeding.

  4. 4
    AI generatedStep 4 of 7

    prepare and submit SECO notifications for affected business relationships, keeping evidence of match rationale, asset-freeze action and notification timing.

  5. 5
    AI generatedStep 5 of 7

    do not treat the SECO report as an AML closure step; document AMLA Article 6 clarifications and file with MROS under AMLA Article 9 where suspicion cannot be dispelled.

  6. 6
    AI generatedStep 6 of 7

    notify front-office, operations, payments, securities, custody and compliance teams that this is an effective-dated sanctions update, not a general advisory.

  7. 7
    AI generatedStep 7 of 7

    test that vendor and internal watchlist feeds have incorporated the amended SESAM content before relying on automated screening results.

Timeline

publication

Aug 17, 2026

EAER/WBF changed the list of sanctioned persons, companies and organisations; SECO adjusted SESAM and published the adjustment on its website.

publication

Aug 18, 2026

FINMA published its updated sanctions notice for the Islamic Republic of Iran.

effective date

Date not specified

The amendment to the Iran sanctions annexes enters into force.

Sources

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

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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