FINMA

Swiss Financial Market Supervisory Authority

Medium Impact

FINMA: Updated Swiss sanctions notice for Moldova list changes effective 12 August 2026 at 23:00

Published

Aug 12, 2026

Effective

Aug 12, 2026

Topics

Sanctions, Moldova, Asset freeze, SECO reporting, AML escalation, Screening reference data

Executive Summary

FINMA published an updated sanctions notice confirming that the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended the annex to the Ordinance of 28 June 2023 on measures concerning Moldova (SR 946.231.156.5). The WBF changed the list of sanctioned persons, companies and organisations on 10 August 2026, and SECO has updated the Swiss authoritative sanctions database, SESAM. FINMA states that the changes are published on SECO’s website and enter into force on 12 August 2026 at 23:00. Financial intermediaries are required, under the ordinance, to implement the prohibitions, freeze assets of sanctioned persons and report affected business relationships to SECO. FINMA also confirms that a SECO sanctions report does not remove separate AML duties: where suspicion indicators exist, firms must conduct additional enquiries under Article 6 AMLA and, if suspicions cannot be dispelled, immediately report to the Swiss Money Laundering Reporting Office under Article 9 AMLA. This is primarily a sanctions-list, screening and case-management update.

What Changed

modifiedMoldova sanctions annex

The prior annex and sanctions list under SR 946.231.156.5 applied before the WBF’s 10 August 2026 list change.

New

The amended list is reflected in SECO’s SESAM database and is published by SECO for Swiss sanctions compliance.

modifiedSESAM sanctions reference data

Screening systems using the earlier SESAM Moldova list may not identify the newly amended sanctioned parties.

New

Financial intermediaries should screen against the updated SESAM Moldova data from the effective time.

modifiedImplementation timing

No effect for the 12 August 2026 changes before the stated entry-into-force time.

New

The changes take effect on 12 August 2026 at 23:00 Swiss time.

modifiedSECO reporting and AML escalation

Sanctions reporting and AML suspicious activity reporting may have been treated operationally as linked case workflows.

New

A SECO notification is required for affected relationships, while Article 6 AMLA enquiries and Article 9 AMLA reporting to MROS remain separately assessable.

Business Impact

Who is affected

Directly affected

Swiss financial intermediaries subject to the Moldova sanctions ordinance, including banks, securities firms, asset managers, portfolio managers, trustees, insurers and other regulated intermediaries with customer, payment, custody, trade finance or investment screening obligations.

Indirectly affected

group sanctions teams, foreign branches or affiliates relying on Swiss sanctions controls, vendors operating screening engines, customers, counterparties and beneficial owners subject to rescreening or asset-freeze case review.

Jurisdictions

Switzerland

Business processes

Sanctions list ingestion and watchlist governance, Customer, beneficial owner and counterparty rescreening, Payment, securities, custody and trade-finance sanctions screening, Asset-freeze and blocked-asset case management, SECO notification of affected business relationships, AML enquiries under Article 6 AMLA and MROS escalation assessment under Article 9 AMLA

Estimated effort

Low

Compliance risk

High

Affected Reports

SESAM-based sanctions watchlist/reference-data update controlMoldova sanctions rescreening exception reportAsset-freeze or blocked-assets case registerSECO notification file for affected business relationshipsAML suspicion enquiry and MROS escalation assessment record

Field	Validation rule
Sanctions programme / legal basis	Classify the update under the Swiss Moldova sanctions regime, SR 946.231.156.5, as referenced in FINMA’s notice.
Sanctions-list party type	Apply the updated list to persons, companies and organisations, the categories FINMA states were changed by the WBF.
Effective timestamp	Use 2026-08-12 23:00 Swiss time as the operative time for the updated measures.
Case reporting destination	Route affected business-relationship reports to SECO; separately assess whether unresolved suspicion indicators require an MROS report under Article 9 AMLA.

Recommended Actions

7 suggested next steps· derived from source analysis

1
Confirmed actionStep 1 of 7
load the updated SECO SESAM Moldova list into sanctions screening tools and evidence the timestamp of production deployment.
2
Confirmed actionStep 2 of 7
rescreen customers, beneficial owners, counterparties, payments, securities positions and open cases that are within the firm’s sanctions-screening perimeter.
3
Confirmed actionStep 3 of 7
freeze assets and implement applicable prohibitions for confirmed sanctioned-party exposure from the 12 August 2026 23:00 effective time.
4
Confirmed actionStep 4 of 7
notify SECO of any affected business relationships identified under the ordinance.
5
Confirmed actionStep 5 of 7
do not treat SECO notification as closing AML obligations; perform Article 6 AMLA enquiries and file with MROS under Article 9 AMLA if suspicions cannot be dispelled.
6
AI generatedStep 6 of 7
retain an auditable evidence pack covering source notice, list version, matching logic, false-positive disposition, freeze decisions and regulatory notifications.
7
AI generatedStep 7 of 7
inform sanctions operations, relationship management and payment operations that this is an immediate reference-data change rather than a policy consultation.

Timeline

other

Jun 28, 2023

Ordinance on measures concerning Moldova dated 28 June 2023, as referenced by FINMA.

implementation

Aug 10, 2026

WBF changed the list of sanctioned persons, companies and organisations in the Moldova sanctions context.

publication

Aug 12, 2026

FINMA published the updated Moldova sanctions notice and stated that SECO would publish the SESAM adjustments on its website.

effective date

Aug 12, 2026

The amended measures enter into force at 23:00 Swiss time.

Sources

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

Official regulator news noticeFINMAAug 12, 2026
Aktualisierte Sanktionsmeldung: Moldau ↗
https://www.finma.ch/en/news/2026/08/20260812-sr-946-231-156-5
Official government sanctions information pageState Secretariat for Economic Affairs SECODate not specified
Sanctions/Embargoes ↗
https://www.seco.admin.ch/seco/en/home/Aussenwirtschaftspolitik_Wirtschaftliche_Zusammenarbeit/Wirtschaftsbeziehungen/exportkontrollen-und-sanktionen/sanktionen-embargos.html
Primary legislationFedlex / Swiss ConfederationOct 10, 1997
Federal Act on Combating Money Laundering and Terrorist Financing ↗
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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