FINMA Sanctions Update: Ukraine and Moldova Lists Change 10 August

On 12 August 2026, FINMA published two sanctions notifications on the same day: one on Switzerland’s Ukraine ordinance (SR 946.231.176.72) and one on its Moldova ordinance (SR 946.231.156.5). Both notices concern EAER amendments made on 10 August 2026. SECO and Fedlex state that the measures entered into force at 23:00 on 11 August 2026. The FINMA pages are dated 12 August and state that the measures enter into force ‘today at 23:00’, so their relative-date wording is inconsistent with the Fedlex and SECO effective-date record. FINMA published the notices to financial intermediaries, but the legal prohibitions, freezing and reporting duties arise under the ordinances from their effective date. The notices do not themselves create a separate screening obligation.

The instruction in both notices is short and identical. Financial intermediaries are called on to implement the prohibitions in the ordinance, block the assets of the listed persons, and report the affected business relationships to the State Secretariat for Economic Affairs (SECO). What the two notices add, and what a compliance team should read carefully, is the reminder that reporting a frozen relationship to SECO does not discharge the separate duties under the Anti-Money Laundering Act.

Related reading: FINMA’s Taliban sanctions update and the SESAM database.

Key dates in the two FINMA sanctions updates

• 10 August 2026: the EAER amends Annex 2 and Annex 8 of the Ukraine ordinance (SR 946.231.176.72) and the designation list in the Moldova ordinance (SR 946.231.156.5).
• 11 August 2026 at 23:00: the amended measures enter into force.
• 12 August 2026: FINMA publishes both sanctions notifications to supervised institutions.

What the EAER amended on 10 August

The Ukraine amendment changes two different sanctions sets. Annex 8 is the list used for Article 15 financial sanctions and Article 29 entry and transit measures, while Annex 2 identifies the end recipients subject to the goods-movement and transit restrictions that govern that annex. The applicable consequence therefore depends on the annex and governing provision; an Annex 2 match is not, by that fact alone, an Article 15 asset-freeze case. For the Moldova ordinance, SR 946.231.156.5 of 28 June 2023, the amendment updated the list of sanctioned persons, companies and organisations.

A newly listed person or entity becomes subject to the amended measure when that measure enters into force. SECO publishes a current consolidated list, but the ordinance annexes remain the legal source and SECO’s search tool does not provide information on possible ownership or control relationships. This is the same block-and-report chain that ran in FINMA’s Sudan and South Sudan sanctions update: the legal trigger is the entry into force of the ordinance amendment, while the FINMA notification communicates the change. The ordinance annexes are the legal source; SECO also publishes the current consolidated list for operational use.

From a screening alert to a confirmed match

The freeze provisions extend beyond a direct name match: they also cover the relevant funds and economic resources of enterprises and organisations that are owned or controlled by listed persons, enterprises or organisations. A name that pings against the refreshed Ukraine or Moldova list is a candidate to be checked against the ordinance entry, using the identifiers the annex gives, before any account is blocked. An alert prompts verification; confirmation against the ordinance entry is what triggers the freeze.

That distinction matters most on the near-misses. A common surname, a transliterated company name, or a partial date-of-birth hit can look like a designation without being one. Where the identifiers confirm the listing, the block and the SECO report follow. Where the identifiers do not resolve the sanctions alert, further sanctions analysis may be needed. The AMLA Article 6 track applies where there are grounds for suspicion; the notices do not state that every unresolved name-screening alert is itself an Article 6 trigger.

Why the SECO report does not close the AMLA file

Both notices state that reporting to SECO does not release a financial intermediary from making additional clarifications under Article 6 of the Anti-Money Laundering Act where there are grounds for suspicion, and, if the intermediary cannot dispel that suspicion, from filing a report without delay with the Money Laundering Reporting Office (MROS) under Article 9. The embargo duty and the money-laundering duty are separate obligations that can arise from the same account.

Read the two tracks as parallel filings to different authorities. The SECO report discharges the ordinance obligation to notify a blocked relationship. The Article 9 report to MROS discharges the AMLA obligation where a suspicion of money laundering or terrorist financing cannot be cleared. A single sanctions match can require both, one, or, once identifiers confirm no listing, neither. Treating the SECO notification as a suspicious activity report is the misread the notices are written to prevent.

Which list a Switzerland-regulated firm screens against

Swiss sanctions ordinances are autonomous instruments issued under the Embargo Act. Switzerland frequently adopts EU sanctions measures, but Swiss adoption is not automatic: the Federal Council decides case by case whether to adopt EU measures in full, in part or not at all. For Swiss compliance, the applicable Swiss ordinance and SECO materials govern.

The sanctions duties are defined by the ordinances, while AMLA separately defines the financial intermediaries subject to Articles 6 and 9. FINMA monitors AMLA compliance directly for some institutions and indirectly through supervisory or self-regulatory organisations for others. For those firms, sanctions screening and AMLA due diligence sit in the same operating model, much as they do in Sweden’s 2026 AML/CFT and sanctions risk priorities, where a supervisor sets out how it expects screening to be evidenced.

Frequently Asked Questions

We already report the frozen relationship to SECO. Does that also satisfy our reporting duty to MROS?

No. The notices state that the SECO report does not release the intermediary from the Article 6 clarification duty or, where suspicion cannot be dispelled, the Article 9 report to MROS. The two go to different authorities and answer different questions, one about the embargo and one about money laundering, and a single freeze can trigger both.

We screen against the EU and UN consolidated lists. Is that enough for Switzerland?

The applicable Swiss ordinance is legally controlling. SECO publishes a consolidated list and search tools for operational use, but its search engine is a support tool and does not show possible ownership or control relationships. EU or UN screening alone therefore does not establish compliance with the applicable Swiss ordinance.

The EAER amended the lists on 10 August, the measures entered into force at 23:00 on 11 August, and FINMA published on 12 August. Which date drives the sanctions duties?

The ordinance effective date. SECO and Fedlex place entry into force at 23:00 on 11 August 2026. FINMA’s 12 August notification therefore followed the legal effective time; the notice itself did not create the duties.

A client name matches the updated Moldova list, but the identifiers do not fully line up. Do we freeze at once?

The freeze duty attaches to funds and economic resources of the listed person or entity, so the alert is verified against the ordinance entry first. If the unresolved alert also gives rise to grounds for suspicion, Article 6 additional clarifications apply and, if that suspicion cannot be dispelled, the FINMA notices say an Article 9 report to MROS must be made without delay.

Related Articles

• FINMA Sudan and South Sudan Sanctions Update: another SECO-list refresh that runs the same block-and-report chain for supervised firms.
• FINMA Taliban Sanctions Update and the SESAM Database: how a designation reaches supervised firms through SECO’s sanctions administration.
• EU Sanctions Screening under Council Regulations 2026/1708 and 1710: EU restrictive measures and consolidated list structure, for comparative context on how Swiss and EU sanctions instruments interact.
• Sweden 2026 AML/CFT and Sanctions Risk Priorities: how another European supervisor frames its screening and reporting expectations.

Key Takeaways

• The Ukraine (SR 946.231.176.72) and Moldova (SR 946.231.156.5) designation lists changed on 10 August 2026; re-screen the active book against the updated SECO list.
• The block and reporting duties attach from 23:00 on 11 August 2026, the ordinance effective time, not from FINMA’s 12 August notification.
• Report affected business relationships and blocked assets to SECO, as the ordinances require.
• A SECO report does not discharge the Anti-Money Laundering Act duties: run Article 6 clarifications where suspicion arises, and file an Article 9 report to MROS if it cannot be dispelled.
• Confirm a screening alert against the ordinance entry before freezing; a partial name match is a candidate, not the freeze trigger.
• Screening only EU or UN lists does not establish compliance with Swiss sanctions law; the applicable Swiss ordinance is legally controlling, with SECO’s consolidated list and tools available for operational use.

Sources and References

• FINMA, Updated sanctions notification, Ukraine ordinance (SR 946.231.176.72), 12 August 2026
• FINMA, Updated sanctions notification, Moldova ordinance (SR 946.231.156.5), 12 August 2026
• Fedlex, Ordinance of 4 March 2022 on measures relating to the situation in Ukraine (SR 946.231.176.72)
• Fedlex, Ordinance on measures concerning Moldova (SR 946.231.156.5), current consolidated text
• FINMA, Money laundering and sanctions dossier
• FINMA, Combating money laundering in the context of financial market supervision

What to do before your next screening run

The two notices communicate changes to the sanctions data used to implement the ordinances; they do not themselves prescribe a separate screening or re-screening process. The concrete next step is to confirm that the screening engine has ingested the 10 August 2026 amendments and to route each confirmed match according to the relevant sanction set and governing provision. Ukraine Annex 8 and Moldova asset-freeze cases should be handled under their applicable freezing and SECO reporting provisions; Ukraine Annex 2 matches must instead be assessed against the end-recipient restrictions that govern that annex. Any case that separately gives rise to AMLA suspicion should be assessed under Articles 6 and 9. The date to hold against the file is 11 August 2026 at 23:00, the moment the measures took effect.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.