FINMA

Swiss Financial Market Supervisory Authority

Medium Impact

FINMA Ukraine sanctions update: WBF amends Annexes 2 and 8, effective 12 August 2026 at 23:00

Published

Aug 12, 2026

Effective

Aug 12, 2026

Topics

Sanctions, Ukraine, Russia-related sanctions, Asset freezing, SECO reporting, AML reporting, Financial intermediaries

Executive Summary

FINMA has issued an updated Ukraine sanctions notification after the Federal Department of Economic Affairs, Education and Research (WBF/EAER) amended Annexes 2 and 8 to the Ordinance of 4 March 2022 on measures connected with the situation in Ukraine, SR 946.231.176.72. According to FINMA, WBF made the amendments on 10 August 2026, published them on its website on 12 August 2026, and the measures enter into force on 12 August 2026 at 23:00. FINMA calls on financial intermediaries to implement the prohibitions under the ordinance, freeze assets of sanctioned persons and report affected business relationships to SECO. The notice also confirms that a SECO sanctions report does not replace anti-money laundering duties: where suspicion indicators exist, intermediaries must conduct additional clarifications under Article 6 AMLA and, if suspicion cannot be dispelled, immediately file a report with the Money Laundering Reporting Office Switzerland under Article 9 AMLA. Firms should treat this as a same-day sanctions data, screening and escalation update.

What Changed

modifiedAnnexes 2 and 8 to the Ukraine measures ordinance amended

The prior versions of Annexes 2 and 8 applied before the WBF amendment of 10 August 2026.

New

The amended Annexes 2 and 8, as published by WBF on 12 August 2026, apply from the stated entry-into-force time.

modifiedSame-day entry into force

Pre-amendment sanctions controls applied until the new measures became effective.

New

Controls must reflect the amended measures from 12 August 2026 at 23:00.

modifiedFinancial intermediary implementation expectations

Financial intermediaries were required to comply with the existing prohibitions, freezing and SECO reporting duties under the ordinance.

New

Those duties must be applied to business relationships and assets affected by the amended Annexes 2 and 8.

modifiedAML obligations remain separate from SECO sanctions reporting

AMLA clarification and suspicious activity reporting duties already applied independently of sanctions reporting.

New

Firms must continue to assess AMLA Article 6 and Article 9 duties separately when sanctions-related suspicion indicators arise.

Business Impact

Who is affected

Directly affected

Swiss financial intermediaries subject to the Ordinance and FINMA-supervised institutions with customers, assets, transactions or business relationships linked to sanctioned persons or prohibited activity under Annexes 2 and 8.

Indirectly affected

group sanctions-screening, payments, custody, trade finance, client onboarding/KYC, correspondent banking, external asset managers and technology/data vendors supporting Swiss operations.

Jurisdictions

Switzerland, Swiss-booked cross-border business affected by Swiss Ukraine sanctions controls

Business processes

Sanctions list ingestion and reference-data governance, Customer, beneficial-owner and counterparty screening, Payments, securities, custody and trade finance sanctions controls, Asset-freeze and transaction-blocking workflows, SECO sanctions reporting workflow, AMLA Article 6 clarification and Article 9 MROS escalation

Estimated effort

Medium

Compliance risk

High

Affected Reports

SECO report of affected business relationships under the Ukraine measures ordinanceInternal asset-freeze and blocked-assets register/control logSanctions screening watchlist update and match-resolution controlAMLA Article 6 additional clarification record where suspicion indicators existMROS suspicious activity report under AMLA Article 9 where suspicion cannot be dispelled

Field	Validation rule
Ukraine sanctions screening reference data - Ordinance SR 946.231.176.72 Annex 2	Update the internal reference dataset to the WBF-published amended Annex 2; the FINMA notice does not identify individual entry-level field changes.
Ukraine sanctions screening reference data - Ordinance SR 946.231.176.72 Annex 8	Update the internal reference dataset to the WBF-published amended Annex 8; the FINMA notice does not identify individual entry-level field changes.

Recommended Actions

6 suggested next steps· derived from source analysis

1
AI generatedStep 1 of 6
Obtain the WBF/SECO-published amended Annexes 2 and 8 from official sources, load them into sanctions-screening systems, and retain evidence of the update time.
2
AI generatedStep 2 of 6
Rescreen customers, beneficial owners, counterparties, open alerts, payments, securities/custody positions and relevant trade finance exposures against the amended Annexes 2 and 8.
3
AI generatedStep 3 of 6
For confirmed matches, apply transaction prohibitions, freeze affected assets and file the required report of affected business relationships with SECO.
4
AI generatedStep 4 of 6
Separately assess whether any sanctions hit or related facts require Article 6 AMLA clarifications and, if suspicion cannot be dispelled, an immediate Article 9 AMLA report to MROS.
5
AI generatedStep 5 of 6
Notify front-office, operations, payments, custody and compliance teams of the 12 August 2026 23:00 effective time and any interim hold/release rules.
6
AI generatedStep 6 of 6
Monitor FINMA and SECO for any further Ukraine sanctions publications, corrected annex files or operational guidance linked to this update.

Timeline

other

Aug 10, 2026

WBF amended Annexes 2 and 8 of the Ordinance of 4 March 2022 on measures connected with the situation in Ukraine.

publication

Aug 12, 2026

FINMA published the updated Ukraine sanctions notification and stated that WBF published the amendments on its website on the same date.

effective date

Aug 12, 2026

The amended measures enter into force.

Sources

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

Official regulator newsFINMAAug 12, 2026
Aktualisierte Sanktionsmeldung: Ukraine ↗
https://www.finma.ch/en/news/2026/08/20260812-sr-946-231-176-72
Official sanctions programme pageState Secretariat for Economic Affairs SECODate not specified
Ukraine: measures ↗
https://www.seco.admin.ch/seco/en/home/Aussenwirtschaftspolitik_Wirtschaftliche_Zusammenarbeit/Wirtschaftsbeziehungen/exportkontrollen-und-sanktionen/sanktionen-embargos/sanktionsmassnahmen/ukraine.html
Primary legal textFedlex / Swiss ConfederationMar 4, 2022
Ordinance on measures connected with the situation in Ukraine, SR 946.231.176.72 ↗
https://www.fedlex.admin.ch/eli/cc/2022/151/en
Primary legal textFedlex / Swiss ConfederationOct 10, 1997
Federal Act on Combating Money Laundering and Terrorist Financing, 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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