SECO sanctions list: how the Swiss sanctions list works (2026)

Last reviewed: 22 October 2026 · Not legal advice

If you onboard customers in Switzerland, the SECO sanctions list is the Swiss sanctions list you screen against. It is not one law: Switzerland has 28 sanctions ordinances, enacted by the Federal Council, and the economic affairs department may update their annexes of listed names, which change regularly.^[1][4][6]

The SECO sanctions list at a glance

What the SECO sanctions list is

The Embargo Act is a framework law: it sets the purpose, powers, information duties, data protection and penalties, while the sanctions themselves sit in separate ordinances.^[20][1] Those annexes carry the names of the individuals, groups and companies affected, and the Swiss Financial Market Supervisory Authority (FINMA) notes that they are "updated continuously".^[17]

SESAM is expanded in a note to the Federal Council's 2016 ordinance as "SECO Sanctions Management"; SECO's search page filters the listed subjects by programme, from Belarus, Iran and the situation in Ukraine to ISIL (Da'esh) and Al-Qaida, the Taliban and Syria.^[7][9]

For most programmes the official compilations of federal law do not print the names: the Ukraine ordinance publishes Annex 8 "by reference only" (our translation), and UN list entries such as those of the ISIL and Al-Qaida ordinance are not published there either.^[3][9] The legal text of the names sits in the annexes; SESAM is where the Switzerland sanctions list is searchable. Each record carries an SSID, SECO's "Swiss sanctions identifier", plus dates of birth, places of birth and aliases where known.^[8] That identifier is what you store when you document a match.

The legal basis: the Embargo Act and the ordinances

Article 1 sets whose sanctions Switzerland can implement (Fedlex English translation, no legal force):^[1]

Article 1(1)Embargo Act (EmbA), SR 946.231

"The Confederation may enact compulsory measures in order to implement sanctions that have been ordered by the United Nations Organisation, by the Organisation for Security and Cooperation in Europe or by Switzerland's most significant trading partners and which serve to secure compliance with international law, and in particular the respect of human rights."

Source: Fedlex, Embargo Act, English translation^[1]

In practice the "most significant trading partners" means the EU, says SECO, and the Embargo Act gives no legal basis for sanctions of Switzerland's own making.^[4] Measures may restrict goods, services, payments, capital and the movement of persons, and include prohibitions and reporting duties.^[1]

How Switzerland adopts UN and EU sanctions

Since joining the UN in 2002, Switzerland is bound under international law to implement the Security Council's non-military sanctions.^[5] Since a Federal Council ordinance of 4 March 2016, changes to UN sanctions lists are "directly legally valid" (our translation) in Switzerland, with no new decision needed.^[6][9] According to the note in that ordinance, SECO enters UN changes in SESAM as a rule one working day after the UN notifies them.^[9]

EU sanctions follow another path. There is no automatism: the Federal Council decides case by case whether Switzerland adopts EU sanctions in full, in part or not at all.^[4] Because every adoption needs that decision, SECO says Swiss measures come "with a time lag" (our translation) behind the EU.^[4]

The two routes into the SECO sanctions list.

The 20th EU package against Russia, adopted on 23 April 2026, shows the lag: 115 Swiss listings followed on 22 May 2026 and the other measures took effect on 20 August 2026.^[10] For Belarus, two companies were listed on 22 May 2026 and the remaining measures of the same EU date took effect on 19 September 2026.^[11]

1. 1 Jan 2003Embargo ActThe framework law takes effect.
2. 4 Mar 2016UN lists automaticUN list changes apply without a new decision.
3. 4 Mar 2022Ukraine ordinanceThe current Russia ordinance.
4. 20 Aug 202620th packageThe latest Russia package applies.
5. 1 Oct 2026AMLA covers sanctionsFinancial intermediaries must organise against sanctions breaches.

Milestones of the Swiss sanctions framework.^{[1][9][3][10][15]}

Searching and downloading the list in SESAM

SECO's page "Searching for subjects of sanctions and overall list" offers a search engine and the complete list.^[7] You search by name, programme and subject type (person, organisation or ship).^[7] The name search is fuzzy, so spelling variants and common misspellings are accepted, and results are sorted by quality of match.^[8]

Four limits matter. SECO says the search engine "is provided solely as a support tool": it shows only directly sanctioned subjects and gives no information on ownership or control.^[7] The additional data is in English only, so you search "Milan", not "Mailand".^[8] Results follow the date of entry into force, so a subject due for deletion still appears until that date.^[8] And SECO's notices of annex changes typically set entry into force at 23:00 on the day of publication or the next day.^[6]

Who has to comply with Swiss sanctions

Everyone in Switzerland. SECO's own words, in our translation: "Private individuals and companies in Switzerland are obliged to comply with the sanctions in force".^[6]

SECO says, in our translation, that it is "the responsibility of companies and other parties concerned to ensure that the sanctions measures are complied with at all times", including keeping track of changes.^[4] Swiss measures follow the territoriality principle: they apply to persons in Switzerland, while legally independent foreign subsidiaries and Swiss citizens living abroad are usually not covered.^[4] Third-state sanctions, such as US measures, in principle have no direct effect in Switzerland.^[4] Our guide to screening SECO, EU, UN and OFAC (US Office of Foreign Assets Control) lists in Switzerland covers when each list matters.

Freezing and reporting: what the ordinances require

Each ordinance has its own freezing and reporting articles; the Ukraine ordinance (SR 946.231.176.72) is the model most firms know.^[3] Under Article 15, funds and economic resources owned or controlled by the persons in Annex 8 are frozen, as are those of persons acting in their name or on their instruction and of companies they own or control.^[3] It is forbidden to transfer funds to them or to make funds or economic resources available, directly or indirectly.^[3] Under Article 1, "funds" includes crypto-assets.^[3]

Article 16(1)Ukraine ordinance, SR 946.231.176.72 (our translation from the German)

"Persons and organisations that hold or manage funds, or know of funds or economic resources, which must be presumed to fall under the freeze in Article 15(1), must report this to SECO without delay."

Source: Fedlex, Verordnung über Massnahmen im Zusammenhang mit der Situation in der Ukraine^[3]

A report must name the beneficiaries, give the object and value of the frozen funds or resources and, for credits, name the originators.^[3] SECO lists its reporting forms online; questions go in writing to sanctions@seco.admin.ch.^[14][4] Before releasing anything reported as frozen, SECO asks firms to consult it and explain their reasons.^[12] Exceptions, such as humanitarian payments, can be authorised by SECO; delisting requests go to the economic affairs department, not SECO.^[3][4]

Handling a possible hit on the SECO sanctions list.

Ownership and control: the 50% rule in Switzerland

The freeze reaches companies that listed persons own or control, even when the company itself is on no list.^[3] SECO's interpretation guide of 30 June 2026, which it describes as legally non-binding, sets the test.^[12] Ownership exists where a person, in our translation, "directly or indirectly holds 50% or more" of a company, and holdings of several sanctioned persons are added together.^[12]

Control is a separate test. The guide lists eight criteria, among them the power to appoint or remove most of the board, a majority of voting rights, a dominant influence by contract or articles, and the power to dispose of the company's funds; if one is met, control is presumed unless the contrary is proven.^[12] Assets moved to relatives or other third parties stay frozen where there is a founded suspicion that the listed person still controls them.^[12] A person who is not listed but whose account was frozen by a financial intermediary can ask SECO for a contestable ruling on ownership and control.^[13]

SESAM does not show these links, so ownership checks belong to business verification.^[7]

Penalties under the Embargo Act

The Ukraine ordinance shows how the two levels map: breaches of the freeze in Article 15 fall under Article 9 EmbA, breaches of the reporting duty in Article 16 under Article 10 EmbA.^[3] SECO prosecutes and decides under administrative criminal law, the Office of the Attorney General can open an investigation in serious cases at the administrative unit's request, and a contravention is time-barred after five years.^[1] Assets can also be forfeited where their lawful use is not guaranteed.^[1]

According to the law firm CMS, FINMA revoked the licence of a Swiss bank and ordered its liquidation in February 2026, finding among other things that the bank had allegedly helped clients circumvent asset freezes.^[19]

The AMLA link since 1 October 2026

Since 1 October 2026, the date the Transparency of Legal Entities Act and the revised Anti-Money Laundering Act (AMLA, SR 955.0) took effect, the two regimes are linked.^[15][16] Article 1 AMLA now covers due diligence in financial transactions, in our translation "including to prevent breaches of coercive measures under the Embargo Act".^[15] A new Article 29(1bis) lets MROS and SECO exchange the information they need.^[15]

Article 8Anti-Money Laundering Act, SR 955.0 (our translation from the German)

"Financial intermediaries shall take, within their field, the organisational measures necessary to prevent money laundering and terrorist financing and breaches of coercive measures under the EmbG. In particular, they shall ensure adequate staff training and controls."

Source: Fedlex, Geldwäschereigesetz (GwG)^[15]

The two reporting channels still differ. Funds that must be presumed frozen are reported to SECO without delay under the ordinance, without waiting for certainty.^[3] A report to MROS, the Money Laundering Reporting Office at the Federal Office of Police, follows knowledge or founded suspicion of money laundering or terrorist financing, and the customer may not be told about it.^[15] According to CMS, a sanctions hit without other suspicious elements does not by itself trigger an MROS report, while circumvention structures or false information may.^[19] FINMA, for its part, is not the sanctions authority: SECO checks enforcement, and FINMA checks that supervised institutions identify, limit and monitor all risks, sanctions included.^[18][17] Our guide to Swiss AML and KYC requirements covers the AMLA, FINMA and SRO rules in detail.

A screening programme against the SECO list

SECO places the responsibility for compliance on the firm itself, and no SECO or FINMA page we reviewed offers an approval or certification for screening tools.^[4] According to CMS, FINMA's May 2026 consultation report on the AMLO-FINMA lists three measures it considers required on sanctions: a regular risk analysis, internal directives and, depending on size and activity, an IT-supported system that screens business relationships and the originators and beneficiaries of transactions.^[19] The checklist mixes cited legal duties with recommended controls:

• Name SECO in your sanctions policy as a mandatory list for business in Switzerland.^[6]
• Write down which other lists you screen, EU and OFAC included, and why.
• Collect name, date of birth, nationality and document number from a verified document.
• Screen every new customer before the first transaction.
• Re-screen existing customers after list changes, overnight ones included (a recommended control).^[6]
• Store the search inputs, time, results, SSID and reviewer for every check: SESAM does not keep your searches.^[8]
• Apply the 50% aggregation rule to owners of business customers.^[12]
• Freeze and report to SECO without delay once funds must be presumed frozen.^[3]
• Consult SECO before releasing anything reported as frozen.^[12]
• Assess each confirmed match for an MROS report under the AMLA.^[15]
• Train staff and run controls, as Article 8 AMLA requires, and test them regularly.^[15]

How Didit helps you screen against the SECO sanctions list

Didit's AML screening runs as a step in the same verification session as the identity check. The docs list 1,300+ watchlist databases, among them both SECO lists, OFAC SDN, UN, EU and HM Treasury. Matching weighs name, date of birth, nationality and document number, allows for misspellings, and uses thresholds you set. Possible matches go to manual review in the console, and false positives stay in the report for audit.

Once a person is approved, ongoing monitoring re-screens them daily, moves the session to In Review or Declined when a new hit crosses your thresholds, and sends a webhook. Each report records when the subject was last screened and when the lists behind it were last refreshed. For business customers, business verification screens the company, and its owners and officers as people; the documented SECO coverage applies to person screening. Data is processed in the EU by default. Costs are on the pricing page.

Frequently asked questions

Sources

1. Federal Act on the Implementation of International Sanctions (Embargo Act, EmbA), SR 946.231, English translation, Fedlex, status 1 July 2023.
2. Bundesgesetz über die Durchsetzung von internationalen Sanktionen (Embargogesetz, EmbG), SR 946.231, Fedlex, status 1 July 2023.
3. Verordnung über Massnahmen im Zusammenhang mit der Situation in der Ukraine, SR 946.231.176.72, Fedlex, status 21 September 2026.
4. FAQ: Sanktionen der Schweiz, SECO, opened 22 October 2026.
5. Die Schweiz und internationale Sanktionen, SECO, opened 22 October 2026.
6. Allgemeine Informationen Sanktionen and current changes, SECO, opened 22 October 2026.
7. Searching for subjects of sanctions and overall list, SECO, opened 22 October 2026.
8. User guide: Searching for subjects of sanction (SESAM), SECO.
9. Verordnung über die automatische Übernahme von Sanktionslisten des Sicherheitsrats der Vereinten Nationen, Federal Council, 4 March 2016.
10. Ukraine: Der Bundesrat setzt das 20. Sanktionspaket gemäss bisheriger Praxis um, Federal Council, 19 August 2026.
11. Ukraine: Die Schweiz übernimmt weitere Sanktionen der EU gegen Belarus, Federal Council, 18 September 2026.
12. Auslegungshilfe für Sanktionsmassnahmen, SECO, 30 June 2026.
13. Ausnahme- und Delisting-Gesuche, Verfahren zur Feststellung von Eigentums- und Kontrollverhältnissen, SECO, opened 22 October 2026.
14. Meldepflichten: Formulare, SECO, opened 22 October 2026.
15. Geldwäschereigesetz (GwG), SR 955.0, Fedlex, status 1 October 2026.
16. Hinweise zur Revision des GwG und der GwV per 1. Oktober 2026, FINMA, opened 22 October 2026.
17. International sanctions and independent freezing measures, FINMA, opened 22 October 2026.
18. Money laundering and sanctions, FINMA, Risk Monitor 2022 extract.
19. Financial market law obligations of Swiss banks in dealing with sanctions, CMS, 1 June 2026.
20. Rechtliche Grundlagen Sanktionen, SECO, opened 22 October 2026.

See how Didit screens people against 1,300+ watchlist databases, the SECO lists among them, on the AML screening page, or read our page on identity verification in Switzerland.