FINMA Russia Sanctions: The 20 August 2026 Measures

ByRegReportingDesk

On 20 August 2026 FINMA published a short notice reminding supervised financial intermediaries that the Federal Council had, the day before, adopted the further measures of the European Union’s 20th Russia sanctions package. The FINMA Russia sanctions notice points to a decision taken on 19 August 2026, with the new Swiss measures entering into force on 20 August 2026. The document itself is brief; the compliance obligations it sets in motion are substantial.

The notice reminds intermediaries of duties that already exist; it does not create a new reporting return. The legal change sits in the Federal Council’s amendment of the Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72), which the State Secretariat for Economic Affairs (SECO) administers. FINMA’s notice addresses financial intermediaries and calls on them to implement the ordinance prohibitions, freeze affected assets and report affected business relationships to SECO. Portfolio managers and trustees are generally subject to ongoing supervision by FINMA-authorised supervisory organisations; domestic group companies subject to consolidated FINMA supervision are an exception. The 20 August changes must be implemented alongside the existing asset-freeze screening and reporting controls.

FINMA’s 20 August notice is a Swiss notice and does not establish a corresponding Liechtenstein change on that date. Liechtenstein implements EU sanctions autonomously through its own ordinances under the ISG; the applicable Russia/Ukraine instrument is the Ordinance of 10 March 2022 on measures in connection with the situation in Ukraine (LR 946.224.2). Cross-border groups must therefore assess Swiss and Liechtenstein legal updates separately.

Related reading: our FINMA Ukraine and Moldova sanctions update.

What the FINMA Russia sanctions notice actually changes

The trigger is European. The EU Council adopted its 20th package against Russia on 23 April 2026, adding around 120 individual listings and extending sectoral measures under Council Regulation (EU) No 269/2014 (the listings and asset freeze) and Council Regulation (EU) No 833/2014 (the sectoral restrictions). Switzerland mirrors them autonomously through the Ukraine Ordinance, transposing the measures in stages. The Federal Council described the 19 August decision as adopting the “further measures” of the 20th package, after Switzerland had already added 115 individuals and entities to its sanctions list on 22 May.

The dates a reporting officer needs on one line:

  • 23 April 2026: EU adopts its 20th sanctions package.
  • 22 May 2026: Switzerland adds 115 individuals and entities associated with the 20th package. This was not the last Swiss asset-freeze listing expansion before August: SECO records new Annex 8 listings effective on 16 June 2026. Further Annex 8 listings became effective on 11 August 2026.
  • 19 August 2026: Federal Council decides to adopt the further measures of the 20th package.
  • 20 August 2026: the amended Ukraine Ordinance enters into force; FINMA publishes its notice.

As of the notice, around 2,790 natural persons, companies and organisations are subject to the Swiss asset freeze connected to Russia’s war against Ukraine. That is a running total spanning every earlier listing, and the notice attaches no separate count to the 20 August measures. Treat the figure only as FINMA’s approximate count of individuals and entities subject to the Swiss asset freeze; it is not a count of names added on 20 August.

Screening the list is one control; the crypto bans are another

The 20 August measures include activity-based financial prohibitions, while name-based asset-freeze screening remains a separate control. FINMA’s 20 August notice does not announce a new listing round. Screening should therefore use the latest applicable SECO sanctions list, while the new crypto restrictions must be implemented separately as activity restrictions.

Name-screening controls do not by themselves implement either crypto prohibition. The Federal Council describes the new financial measures as a ban on the use of Russian platforms for transferring and exchanging crypto-assets and a prohibition on support for developing certain Russian crypto-assets such as the digital rouble. A firm with crypto-asset exposure has to test its product and counterparty controls against them separately, in the same way it would read FINMA’s crypto custody guidance alongside its sanctions list. The precise legal scope and any exceptions should be assessed against the amended Ukraine Ordinance rather than inferred from the press-release summary.

In Switzerland, the sanctions report and the AML report go to different desks

This is the point the FINMA notice exists to make. Under the Ukraine Ordinance, Article 15 freezes the funds and economic resources of listed persons, and Article 16 requires anyone holding or managing assets that must be presumed to fall under that freeze to report them to SECO without delay. The same duty covers knowledge of such assets held elsewhere, and it extends to notifying SECO of transactions carried out in the two weeks before a listing took effect.

Filing with SECO does not close the anti-money-laundering question. The notice is explicit that a report to SECO does not release an intermediary from carrying out the additional clarifications required under Article 6 of the Anti-Money Laundering Act (the GwG, SR 955.0) where there are grounds for suspicion, and, where those grounds cannot be dispelled, from filing a report without delay with the Money Laundering Reporting Office Switzerland (MROS) under Article 9. One event, a sanctioned counterparty surfacing in the book, can generate two obligations to two authorities on two legal bases. A team that logs the SECO report and treats the AML angle as handled has met half its duty. This is the same SECO reporting channel we described in the FINMA Iran sanctions update.

In Liechtenstein, both freeze reports and AML reports go to the Stabsstelle FIU

Liechtenstein implements the Russia/Ukraine sanctions through its Ordinance of 10 March 2022 on measures in connection with the situation in Ukraine (LR 946.224.2), issued under the ISG. Article 17 requires freeze-related reports to be made without delay to the Stabsstelle FIU; the Office of Economic Affairs is not the recipient of that report. The FMA is a competent supervisory authority for persons subject to due diligence. FMA Communication 2024/2 concerns foreign sanctions law not covered by the ISG and refers to Chapter 17 of FMA Guidance 2018/7 for the ISG sanctions framework.

The legal bases remain separate, but the recipient is not split between two Liechtenstein authorities. Under Article 17 of the Liechtenstein Ukraine sanctions ordinance, freeze-related reports go to the Stabsstelle FIU; under Article 17 of the Due Diligence Act, suspicious-activity reports also go to the Stabsstelle FIU. A Swiss SECO filing does not replace the Liechtenstein report required under the applicable Liechtenstein provision. We walked through the two-country screening split for the FINMA ISIL and Al-Qaida sanctions notice.

Where a near-match trips the duty

Where concrete indications create a grounded suspicion such that it must be assumed the assets fall within Article 15, the Federal Supreme Court has held that the institution must both report them to SECO and keep them frozen; certainty is not required, and the reporting duty and implementation of the freeze operate to the same threshold. A purely technical or fuzzy alert should be investigated promptly, but Article 6 GwG clarifications are a separate AML duty and are not the legal threshold for deciding whether Article 15 assets must remain frozen. For the EU-side screening logic that Swiss and Liechtenstein lists track, see our note on EU sanctions screening obligations.

Frequently Asked Questions

If a listed counterparty surfaces, do we report to SECO or to MROS first?

They are separate legal tests. The Article 15 freeze and Article 16 SECO report apply where it must be assumed that assets are owned or controlled by a listed person and fall within the freeze. The Article 9 GwG duty is assessed separately: where the statutory criteria are met and Article 6 clarifications do not dispel the suspicion, the intermediary must report to MROS without delay. Article 9 covers money laundering and terrorist financing and extends to predicate offences and organised crime.

Our client trades crypto-assets only on a non-Russian exchange. Does the new crypto prohibition apply?

The Federal Council’s 19 August release confirms a ban on the use of Russian platforms for transferring and exchanging crypto-assets and a prohibition on support for developing certain Russian crypto-assets such as the digital rouble. The precise legal scope and any exceptions should be assessed against the amended Ukraine Ordinance rather than inferred from the press-release summary. The asset-freeze and crypto restrictions are separate legal tests: the relationship must be assessed against the applicable asset-freeze prohibitions, while the crypto restrictions must be assessed separately under the amended ordinance. The activity ban and the name screen answer different questions.

A Liechtenstein entity in our Swiss group finds a match. Which authority receives the report?

The Liechtenstein entity reports under Liechtenstein law. A freeze-related report under Article 17 of the Liechtenstein Ukraine sanctions ordinance goes to the Stabsstelle FIU, and a suspicious-activity report under Article 17 of the Due Diligence Act also goes to the Stabsstelle FIU. A Swiss SECO filing by the parent does not satisfy those Liechtenstein duties.

Is a partial name match enough to freeze the account?

Where concrete indications create a grounded suspicion such that it must be assumed the assets are owned or controlled by a listed person and fall within Article 15, the institution must report to SECO under Article 16 and keep the assets frozen; the Federal Supreme Court has confirmed that full certainty is not required. A purely technical or fuzzy alert, without more, does not reach this threshold. Article 6 GwG clarifications remain a separate AML duty where the relevant suspicion indicators are present.

Key Takeaways

  • The Federal Council decided on 19 August 2026 to adopt further measures of the EU’s 20th package, effective 20 August. FINMA’s 20 August notice does not announce a new Article 15 asset-freeze listing round; screening should use the latest applicable sanctions list published by SECO.
  • Where concrete indications create a grounded suspicion such that it must be assumed that assets fall within the Article 15 freeze, the institution must both keep the assets frozen and report them to SECO without delay under Article 16; full certainty is not required.
  • A SECO sanctions report does not displace any Article 6 AMLA clarification duty or, where the grounds for suspicion cannot be dispelled, the duty to report to MROS without delay under Article 9; Article 9 covers money laundering, predicate offences, organised crime and terrorist financing.
  • In Liechtenstein, freeze-related reports under Article 17 of the Ukraine sanctions ordinance and suspicious-activity reports under Article 17 of the Due Diligence Act both go to the Stabsstelle FIU, although they arise under separate legal bases.
  • The new crypto measures (ban on Russian transfer and exchange platforms; prohibition on support for developing certain Russian crypto-assets such as the digital rouble) are conduct prohibitions, not name-screen entries, and need their own control.
  • Notify SECO of relevant transactions carried out in the two weeks before a listing took effect.

Sources and References

Your next screening cycle

For Switzerland, implement the measures effective 20 August 2026 and ensure screening uses the latest applicable SECO sanctions data. For Liechtenstein, use the current Liechtenstein Ukraine sanctions ordinance and route Article 17 freeze-related reports to the Stabsstelle FIU; do not treat the Swiss 20 August measure as a Liechtenstein list update. Keep the sanctions and AML reporting tests separate even where the Liechtenstein recipient is the same FIU. Maintain the procedure so that future Swiss or Liechtenstein sanctions changes are assessed against the applicable local instrument and routed under the correct reporting basis.

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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