FINMA Belarus Sanctions: The 19 September Crypto and Credit Bans

ByRegReportingDesk
RegReportingDesk card: FINMA, Swiss Financial Market Supervisory Authority, Switzerland

On 18 September 2026 the Federal Council amended the Ordinance of 16 March 2022 on Measures against Belarus (SR 946.231.116.9), and the changes took effect in Switzerland on 19 September. FINMA flagged the change in a notice on 25 September. The FINMA Belarus sanctions notice points to a financial package modelled on the Russia regime: a ban on transactions involving certain crypto-assets and central bank digital currencies, including the digital Belarus rouble, and a ban on transactions with crypto-service providers and decentralised platforms established in Belarus.

Switzerland is adopting the remaining measures the EU took against Belarus on 23 April 2026. Liechtenstein amended its own Belarus ordinance, citing the EU’s 23 April decision, with effect from 22 September. For a screening desk, the change moves less through the name lists than through asset types and counterparty attributes, and each jurisdiction sends its freeze reports to a different authority.

Related reading: FINMA Russia Sanctions: The 20 August 2026 Measures, the regime whose crypto rules the Belarus package now mirrors.

Belarus sanctions dates for Swiss and Liechtenstein desks

  • 23 April 2026: the EU adopts the Belarus measures; Liechtenstein’s amending ordinance cites Council Decision (CFSP) 2026/512 of that date.
  • 22 May 2026: the Swiss economics department (EAER) sanctions two entities within its own competence.
  • 18 September 2026: the Federal Council adopts the amendment, published urgently the same day as AS 2026 480.
  • 19 September 2026: the Swiss amendment enters into force.
  • 22 September 2026: Liechtenstein’s amending ordinance, LGBl. 2026 Nr. 317, is issued and in force on publication.
  • 25 September 2026: FINMA publishes its notice.
  • 20 October 2026: the ban on managed security services for Belarusian state bodies and enterprises and anyone acting for them starts in both countries.

The Swiss prohibitions apply from 19 September, so a review of payments and crypto transfers that starts from the date of FINMA’s notice misses six days. For a Liechtenstein entity the start date is 22 September.

What the FINMA Belarus sanctions notice asks of Swiss intermediaries

FINMA’s notice asks financial intermediaries to do three things under the ordinance: apply the prohibitions, freeze the assets of sanctioned persons, and report the affected business relationships to the State Secretariat for Economic Affairs (SECO). It adds that a SECO report does not release an intermediary from making additional clarifications under Article 6 of the Anti-Money Laundering Act (AMLA) where there are grounds for suspicion, or from reporting without delay to the Money Laundering Reporting Office Switzerland (MROS) under Article 9 AMLA if those grounds cannot be dispelled.

A re-run of name screening will surface very little of this change. Part II of AS 2026 480 amends goods annexes and adds two new annexes, 14a and 28, while leaving Annex 13, the list of persons whose assets are frozen, untouched. SECO’s Belarus page, checked on 27 September 2026, still showed 21 May 2026 as the latest modification of the sanctions lists. The new obligations sit in articles that ask what an asset is and where a counterparty is established.

Two crypto prohibitions, two screening questions

New Article 18a prohibits direct or indirect participation in transactions involving the crypto-assets or central bank digital currencies listed in Annex 14a, and any support for developing them. Annex 14a currently names one item: the digital Belarus rouble. A control for this test has to recognise the instrument, whoever the parties to the transfer are.

New Article 18b works on the counterparty. Legal persons, including financial institutions, may not carry out transactions, directly or indirectly, with legal persons, organisations or entities established in Belarus that provide crypto services, or with platforms established there that enable the exchange or transfer of crypto-assets. For natural persons, Article 18b(2) covers direct transactions only. Official activity in Belarus of diplomatic or consular missions of Switzerland or its partners, and of international organisations with immunity, is carved out.

My reading is that Article 18b turns on the provider’s place of establishment. A Belarusian customer of a Swiss provider falls outside this article; restrictions tied to Belarusian nationality or residence sit elsewhere in the ordinance. The data point that matters is the domicile of the counterparty exchange or platform, which a sanctions name list does not carry. Firms that already record where foreign crypto custodians are established, a question covered in our note on FINMA crypto custody guidance 01/2026, can hold the same attribute for exchanges and platforms.

The amendment also rewrites the definition of funds in Article 1(a). It now lists crypto-assets (Kryptowerte); the consolidated text as at 15 September 2025 used the term crypto-based assets. Crypto-assets owned or controlled by an Annex 13 party are therefore funds within the freeze.

Credit and claims enforcement: changes outside the crypto articles

Article 17 now bans the direct or indirect granting of loans and credits with a maturity above 90 days to the recipients listed in Article 16(1)(a) to (d), and participation in such arrangements. The version as at 15 September 2025 referred to loans only.

New Article 24c prohibits doing business with persons, undertakings or organisations listed in Annex 28, which covers parties involved in enforcing certain claims in third countries, and with those who own or control them. Exceptions cover dealings with lawyers and members of the judiciary, transactions needed for pharmaceutical, medical, agricultural and food products, transactions needed for access to court, administrative or arbitration proceedings in Switzerland or an EEA state or for recognising or enforcing a Swiss or EEA judgment or arbitral award, and the payment of damages under Article 27c. In Switzerland the content of Annex 28 is published by reference only; the Liechtenstein version of the annex states that it currently contains no entries.

Article 24c is framed as a business prohibition, while the Article 13 reporting duty is framed around the Article 12(1) freeze. On the text, a future Annex 28 hit raises a prohibition question, and a SECO freeze report follows only if the party also falls within the freeze scope.

Liechtenstein runs its own ordinance and its own dates

Liechtenstein applies Belarus sanctions through the Ordinance of 18 March 2022 on Measures against Belarus (LR 946.223.0), made under the International Sanctions Act (ISG). LGBl. 2026 Nr. 317 inserts Articles 19a and 19b, the counterparts of the Swiss crypto articles, and an identical Annex 14a. Article 19b is drafted as a general prohibition on direct or indirect transactions, without the Swiss split between legal and natural persons.

Two textual differences matter for a Liechtenstein entity. First, the amendment added crypto-assets to Liechtenstein’s definition of funds; the version dated 3 March 2026 did not list them. Second, the transitional carve-outs use 22 September 2026 where the Swiss text says 19 September. The carve-out for receiving payments owed by Annex 15 entities under contracts performed before the cut-off shows it: Swiss Article 23(2)(a)(5) uses 19 September, Liechtenstein Article 24(2)(a)(5) uses 22 September.

Article 2 of the Liechtenstein ordinance reserves the Swiss goods-control, war-material and embargo legislation applicable in Liechtenstein. The financial measures run under the Liechtenstein ordinance, with the Stabsstelle FIU monitoring implementation under Article 29.

Where each freeze report and suspicion report goes

In Switzerland, Article 13 requires persons holding or managing funds, or knowing of funds or economic resources, presumed to fall under the Article 12(1) freeze to report to SECO without delay. Financial institutions that have reported funds they hold or manage send SECO, by 15 February each year, the amounts as at 31 December of the previous year. Each report names the beneficiaries and the object and value of the frozen assets. The freeze reaches assets owned or controlled by Annex 13 parties, by those acting on their behalf or at their direction, and by entities they own or control. The same SECO route runs through other Swiss programmes, as in the FINMA Iran sanctions update.

Liechtenstein’s Article 14 mirrors this with two differences: reports go to the Stabsstelle FIU, and the 15 February annual report applies to banks and securities firms that have reported. Neither country’s new crypto articles carries a reporting clause of its own.

Suspicion reporting is a separate track in both places. In Switzerland it is the Article 6 and Article 9 AMLA route to MROS that FINMA’s notice restates. In Liechtenstein, Article 17(1) of the Due Diligence Act requires a prompt written report to the Stabsstelle FIU where there is suspicion of money laundering, a predicate offence, organised crime or terrorist financing. One Liechtenstein unit therefore receives both reports, under two legal bases, and each needs its own record.

Frequently Asked Questions

Does Annex 14a capture privately issued tokens promoted in Belarus?

Only the digital Belarus rouble is listed. Other crypto-assets come into scope through Article 18b when the counterparty provider or platform is established in Belarus, or through the freeze when an Annex 13 party owns or controls them.

A private client sends crypto from a Swiss exchange to a platform established in Belarus. Who is caught by the Swiss text?

Article 18b(2) bars the natural person from direct transactions with that platform. On the text, the Swiss exchange executing the transfer is a legal person within Article 18b(1), and that paragraph covers indirect as well as direct transactions.

Key Takeaways

  • Add a counterparty-domicile flag for crypto exchanges and platforms; name screening cannot trigger Article 18b.
  • Set the digital Belarus rouble up as a prohibited asset in any system that can hold or route CBDC or tokenised value.
  • For Switzerland, screen loans and credits with a maturity above 90 days against the recipients in Article 16(1)(a) to (d), while applying the exclusion in Article 17(2) and any applicable SECO-authorised exception under Article 17(3). In Liechtenstein, Article 18 applies the same test to the recipients in Article 17(1)(a) to (d), with a trade-financing exclusion in Article 18(2) and exceptions granted by the Government under Article 18(3).
  • Hold separate cut-off parameters per legal entity: 19 September 2026 in Switzerland, 22 September 2026 in Liechtenstein.
  • Build the Annex 28 check with its ownership and control limb now, and load the Swiss annex content from its by-reference publication on Fedlex.

Sources and References

Next Belarus checkpoints: 20 October and 15 February

The managed security services ban starts on 20 October 2026 in both countries. The next annual frozen-asset amounts report, for positions as at 31 December 2026, is due by 15 February 2027: to SECO from Swiss financial institutions that have reported frozen funds, and to the Stabsstelle FIU from Liechtenstein banks and securities firms that have done so. Because both definitions of funds now list crypto-assets, frozen crypto positions reported under Swiss Article 13(1) or Liechtenstein Article 14(1) belong in that return.

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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