FINMA Iran Sanctions Update: The 18 August Freeze List

ByRegReportingDesk

FINMA’s updated Iran sanctions notification of 18 August 2026 marks a precise moment on the clock. At 23:00 that evening, an amendment to Annexes 12, 13 and 14 of the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran (SR 946.231.143.6) took effect. The Federal Department of Economic Affairs, Education and Research (EAER) had changed the list of sanctioned persons, companies and organisations the day before, on 17 August 2026, and adjusted the SECO sanctions database, SESAM, to match. For a Swiss financial intermediary, that timestamp is the operative one for the revised designations: from it, the amended Annexes 12 to 14 govern the applicable prohibitions, asset freezes and SECO reporting duties.

The FINMA Iran sanctions update is, in substance, a change to the freeze list. What changed is the set of names a firm measures its book against; the operative prohibitions remain in place. That makes this a re-screening and freezing exercise rather than a new reporting return to build. The instrument is the same one revised in December 2025; only the annexes carrying the designations were touched.

Liechtenstein firms sit in a different position from what the shared border suggests. They operate under a parallel sanctions regime governed by their own law, with a different competent authority and a different reporting address. For a group booking clients on both sides of the Rhine, 18 August is a prompt to check two lists against two reporting channels.

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

The dates that matter

The calendar for this change has three entries, only one of which is a hard cut-off. SR 946.231.143.6 was adopted on 12 December 2025 as a total revision of Switzerland’s Iran measures. On 17 August 2026, the EAER amended the designations in Annexes 12, 13 and 14 and updated SESAM to match. The amendments entered into force on 18 August 2026 at 23:00. That 23:00 timestamp is the point from which the revised Annexes 12, 13 and 14 apply; the underlying prohibition, freezing and reporting duties already existed under the ordinance.

What the FINMA Iran sanctions update actually changed

The notification amends the annexes that hold the designations, Annexes 12, 13 and 14. A firm that already screens against the Swiss list faces a refreshed reference list and a fixed moment from which that list governs. FINMA’s 18 August notification announces the annex-list change and reiterates the existing freeze and SECO-reporting duties; it does not announce a new reporting return. This sits in the same Swiss notification series as FINMA’s Ukraine and Moldova sanctions update, where a mid-relationship listing change forced the same re-screening call. A designation added or amended during a live relationship forces an immediate decision on funds a firm already holds.

One practical detail decides whether the update is handled cleanly: the timestamp. The amendment took effect at 23:00 on 18 August 2026, so a screening run completed against the pre-amendment list earlier that day does not evidence compliance from that moment. The reference date for the current screen is the entry-into-force time, not the publication date of the notification.

Verification, freezing and reporting

A screening hit opens a verification task, and verification is the heart of any sanctions screening workflow. A screening hit requires prompt verification against the designation data. Article 16 freezes funds and economic resources owned or controlled by a listed person or entity, while the ordinance requires an immediate SECO report where funds or economic resources are considered to fall within that freeze.

The freeze reaches further than the named individual. Swiss sanctions ordinances freeze funds and economic resources owned or controlled by a designated person, and they prohibit making funds or economic resources available to that person, directly or indirectly. So the question after a confirmed match runs past identity to scope: what the person owns or controls that the firm holds. If verification establishes that the hit is not the listed person or entity and no relevant ownership or control nexus applies, the Article 16 freeze does not arise on those facts. Where funds or economic resources are considered to fall within the Article 16(1) freeze, the ordinance requires an immediate report to SECO; the Article 16 freeze and making-available prohibitions apply according to their terms without a separate confirmed-match threshold.

Freeze, report to SECO, and the AMLA duty that does not close with it

The ordinance requires the applicable assets to be frozen under Article 16 and requires an immediate report to SECO where the funds or economic resources are considered to fall within that freeze. SECO is responsible for implementing and monitoring Swiss sanctions. The ordinance requires the relevant report to SECO; firms should use SECO’s current sanctions-reporting instructions for the applicable submission channel. The enabling statute behind the ordinance is the Embargo Act (EmbG, SR 946.231).

FINMA’s notification adds the point that is easy to lose once a freeze is on: the SECO report does not discharge the separate duty under the Swiss Anti-Money Laundering Act (AMLA). Where the facts around a designated client raise suspicion, Article 6 AMLA still requires the intermediary to carry out its special clarifications, and if those cannot dispel the suspicion, Article 9 AMLA requires an immediate report to the Money Laundering Reporting Office Switzerland (MROS). The sanctions channel and the money-laundering channel run in parallel and answer to different authorities. Filing with SECO and closing the file is the error the notification is written to prevent.

Liechtenstein runs the ISG, not this ordinance

A group with a Vaduz booking centre should not fold Liechtenstein into a single Swiss report. Liechtenstein enforces international sanctions under its own International Sanctions Act (Gesetz vom 10. Dezember 2008 ueber die Durchsetzung internationaler Sanktionen, ISG, LR 946.21). It implements United Nations Security Council measures and, on an autonomous basis, adopts European Union restrictive measures, such as the EU’s own Iran measures, through its own ordinances. It does not enact SR 946.231.143.6.

The reporting address differs too. Under Article 20 of Liechtenstein’s Iran Ordinance (LR 946.223.3), persons and organisations that hold or manage, or know of, funds or economic resources considered to fall within the Article 16 freeze must report immediately to the FIU staff unit. The FIU acts as an enforcement authority under the ISG; other authorities may also be competent depending on the ordinance and sanction. For the Iran perimeter, that means a Liechtenstein intermediary screens against the EU and UN designations its national ordinances give effect to, while a Swiss intermediary screens against the SECO list under the Federal Council ordinance. The two lists overlap in intent and can diverge in detail and timing, which is why a shared screening engine tuned to one list is a weak control for the other.

The 18 August Swiss change and any parallel EU-driven move in Liechtenstein are separate legal events, each with its own effective date. Aligning them by eye invites a gap on one side of the border.

Frequently Asked Questions

Does the amendment apply to relationships onboarded before 18 August 2026, or only to new customers?

The freeze can apply to assets already held when a designation becomes effective; it is not limited to newly onboarded relationships. The ordinance does not prescribe a particular screening method or batch re-screening schedule. A relationship opened years ago that now matches an amended designation is in scope from the entry-into-force time.

A client’s name matches a new listing, but I cannot confirm it is the same person. What then?

An uncertain name match requires prompt verification against the listing data. Whether Article 16 applies turns on whether the funds or economic resources are owned or controlled by a listed person or entity; the ordinance’s reporting duty applies where the assets are considered to fall within that freeze. If the surrounding facts raise a money-laundering suspicion that clarifications under Article 6 AMLA cannot dispel, the Article 9 AMLA report to MROS can be due even where no sanctions freeze is triggered.

We already reported a frozen Iran-related relationship to SECO on an earlier listing. Do we report again?

Reassess the relationship against the updated designation and apply the ordinance’s reporting duty to the resulting facts. The ordinance does not state that every listing amendment by itself requires a duplicate immediate report of an already reported relationship. Separately, financial institutions that hold or manage frozen funds must report those amounts to SECO annually by 15 February, measured at 31 December of the preceding year.

Our group books clients in both Zurich and Vaduz. One report or two?

Two regimes. Swiss bookings that match the ordinance are frozen and reported to SECO; Liechtenstein bookings are handled under the ISG and reported to the Liechtenstein FIU. A single group-wide SECO filing does not cover the Liechtenstein leg.

Where is the current list, and how do I know when it moves again?

SECO maintains the sanctions data in SESAM and publishes a searchable sanctions list; FINMA notifies supervised intermediaries of relevant changes through MyFINMA. FINMA provides the notification and MyFINMA alert channel; SECO publishes the current sanctions data and searchable list, while SR 946.231.143.6 is the legally authoritative instrument.

Sources and References

The one action for tonight’s screening run

Re-run the existing Iran book against the updated SECO list from the new entry-into-force time. Route any sanctions case into the applicable freeze and SECO-reporting workflow; where there are money-laundering suspicion indicators, perform the Article 6 AMLA clarifications and, if those cannot dispel the suspicion, report immediately to MROS under Article 9 AMLA. If the group carries a Liechtenstein booking centre, test that booking independently against the applicable designations in Annexes 11 to 14 of Liechtenstein’s Iran Ordinance (LR 946.223.3). Where funds or economic resources fall within Article 16, Article 20 requires the relevant report to the Liechtenstein FIU staff unit.

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.

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