FINMA Sudan and South Sudan Sanctions: Annex 2 Updated 11 August

ByRegReportingDesk

FINMA published two updated sanctions notifications on 11 August 2026, one for Sudan and one for South Sudan, after the Federal Department of Economic Affairs, Education and Research (EAER/WBF) amended Annex 2 of each ordinance. For a Swiss supervised institution, the FINMA notifications are an operational alert that the relevant Annex 2 lists changed. The amendments took effect at 23:00 on 11 August 2026.

The change touches Annex 2 of the Ordinance on measures against Sudan (SR 946.231.18) and Annex 2 of the Ordinance on measures against the Republic of South Sudan (SR 946.231.169.9). Annex 2 is the list of individuals and entities subject to a financial asset freeze. WBF/EAER adjusted the sanctions database SESAM (SECO Sanctions Management) to reflect the Annex 2 amendments, and the FINMA notices record that the changes occurred rather than reproducing the amended lists themselves.

Financial intermediaries must implement the applicable prohibitions, freeze assets falling within the ordinances’ freeze scope, and report affected business relationships to SECO as required by the ordinances. Firms established in Liechtenstein sit outside the FINMA notice and act under a separate legal track, covered below.

Related reading: FINMA Taliban Sanctions Update: SECO and SESAM

The operative dates

EAER/WBF amended Annex 2 of both ordinances on 10 August 2026, and SESAM was updated accordingly. FINMA published the two notifications on 11 August 2026, and SECO posted the amendment urgently on its own website the same day. The notifications record an entry-into-force of 23:00 on 11 August 2026, with no transitional compliance window. The amendments took effect at 23:00 on 11 August 2026. From that time, Article 2 governs which funds and economic resources are frozen.

What the FINMA Sudan and South Sudan sanctions notifications changed

Both notifications report the same mechanical event: Annex 2 of the relevant ordinance was amended and SESAM was updated to reflect it. Annex 2 holds the names of persons, companies and organisations whose funds and economic resources are frozen under the Swiss measures. An Annex 2 change can alter either the set of listed parties or the data attached to an existing entry.

The line-by-line changes and affected names are published by SECO and reflected in SESAM, which FINMA describes as the sanctions database relevant for Switzerland. Reading names off the FINMA news item, or waiting for a consolidated third-party list to catch up, leaves a gap on the day the change bites. Operationally, firms should update screening data from the current SECO/SESAM list and re-screen existing exposure where needed to identify funds, economic resources or business relationships affected by the amended entries.

FINMA relays the change; SECO implements the sanctions ordinances

FINMA’s own description of its role is narrow: it publishes financial coercive measures and freezing measures on its website, and MyFINMA notifies financial intermediaries of relevant changes. SECO implements the sanctions ordinances. The 11 August 2026 FINMA notices attribute the Annex 2 amendments and the corresponding SESAM adjustments to WBF/EAER.

The practical division matters. SECO receives the freeze report and administers the freeze; FINMA supervises whether an institution has adequate systems to catch and handle sanctions exposure. The FINMA notification is the alert that a change has occurred; the freeze report itself belongs with SECO.

Two ordinances, two United Nations bases

Sudan and South Sudan are separate regimes with separate lists. The Sudan measures rest on SR 946.231.18; the current ordinance implements UN Security Council Resolutions 1556 (2004) and 1591 (2005), while SECO also identifies additional EU measures of 9 October 2023. The South Sudan measures rest on SR 946.231.169.9; SECO identifies UN Security Council Resolution 2206 (2015) together with additional EU measures of 10 July 2014 and 2 February 2018. A screening configuration that folds both countries into a single “Sudan” rule set can miss a South Sudan designation, or apply a stale list to one country while updating the other. Each ordinance and its Annex 2 should be referenced on its own line in the screening logic. Cross-border groups running one screening engine for Swiss and Liechtenstein entities must also reconcile two legal sources and two effective-date calendars; Liechtenstein enforces the measures through its own instruments, administered on a separate calendar.

Freeze obligations and the Embargo Act framework

The Embargo Act of 22 March 2002 (SR 946.231) is the framework statute, and the country ordinances carry the operative freeze and disclosure duties. Under that framework, a person or institution that holds or manages funds, or that is aware of economic resources, likely to be caught by the freeze must report to SECO without delay. The ordinances define economic resources as assets of every kind, other than funds, that can be used to obtain funds, goods or services. Article 6 separately covers persons and institutions that hold or manage funds, or know of economic resources, that are to be assumed to fall within the Article 2 freeze.

The compliance framing is worth keeping precise. Article 2 defines which funds and economic resources are frozen. Article 6 separately requires persons and institutions that hold or manage funds, or know of economic resources, that are to be assumed to fall within the freeze to report them to SECO without delay.

Why Liechtenstein firms follow a separate track

A FINMA notification has no legal effect in Liechtenstein. Liechtenstein enforces international sanctions under its own International Sanctions Act (ISG), the Law of 10 December 2008, and issues its own ordinances to implement United Nations measures, including those on Sudan and South Sudan. The Financial Market Authority Liechtenstein (FMA) supervises how financial intermediaries manage that exposure. A Liechtenstein institution tracks the Liechtenstein instruments and their effective dates, which are administered separately from the Swiss ordinances even when both give effect to the same UN resolutions. Cross-border groups that screen Swiss and Liechtenstein entities on one engine must reconcile two legal sources and two effective-date calendars; the two regimes operate on separate calendars even where the underlying UN measures are the same.

Frequently Asked Questions

Does an amended Annex 2 require re-screening of existing clients, or only new onboarding?

The freeze can apply to funds and economic resources already held or managed. Institutions therefore need controls capable of identifying affected existing exposure as well as new relationships; re-screening is an operational control response rather than a separately stated statutory re-screening deadline.

If a name matches, is a report to MROS also needed, or only to SECO?

The sanctions report to SECO is a distinct obligation from a suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under the Anti-Money Laundering Act. Where funds or economic resources fall within the sanctions ordinance’s freeze scope, the sanctions duties apply. Any MROS reporting duty is assessed separately under the Anti-Money Laundering Act; FINMA expressly states that a SECO report does not remove the duties under Articles 6 and 9 AMLA where the relevant suspicion thresholds are met.

Does the Swiss change alter obligations for an EU or UK entity in the same group?

EU and UK sanctions lists are set by their own authorities; a Swiss ordinance change has no effect on them. A group entity in those jurisdictions screens against applicable EU or UK measures.

Key Takeaways

  • FINMA published two updated sanctions notifications on 11 August 2026, Sudan (SR 946.231.18) and South Sudan (SR 946.231.169.9), each amending Annex 2, with effect from 23:00 that day and no transitional window.
  • SESAM is the sanctions database relevant for Switzerland; update screening data from the current Annex 2 content and ensure controls can identify affected existing exposure as well as new relationships.
  • Freeze funds and economic resources that fall within Article 2, and make any report required by Article 6 to SECO without delay.
  • Configure screening to treat Sudan and South Sudan as separate ordinances and separate lists; Liechtenstein entities within the same group consult the applicable ISG ordinances and FMA guidance.

Sources and References

What to reconcile before the next screening run

The action list is short and dated. Pull the current Annex 2 content for both ordinances from SESAM and ensure screening controls reflect the lists effective from 23:00 on 11 August 2026. Funds and economic resources within the Article 2 freeze scope must be frozen, and any Article 6 report to SECO must be made without delay. Liechtenstein entities in the same group should follow the applicable Liechtenstein ISG ordinances and their own effective dates.

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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