EAER updates Sudan sanctions list with same-day effect

The Swiss Federal Department of Economic Affairs, Education and Research (EAER) amended Annex 2 to the 25 May 2005 Ordinance on measures against Sudan (SR 946.231.18) on 2 November 2026. In a 3 November notice, the Swiss Financial Market Supervisory Authority (FINMA) said the urgent changes entered into force that day at 23:00. EAER also updated SESAM, the SECO Sanctions Management database used for Switzerland’s sanctions information.

The notice asks financial intermediaries to implement the ordinance’s prohibitions, freeze the assets of sanctioned persons and report affected business relationships to the State Secretariat for Economic Affairs (SECO).

AML duties continue after the sanctions report

Reporting a relationship to SECO does not end the intermediary’s obligations under Switzerland’s Anti-Money Laundering Act. The notice says firms must carry out additional clarification where there are suspicions under Article 6 AMLA. If those suspicions cannot be dispelled, they must report without delay to the Money Laundering Reporting Office Switzerland under Article 9 AMLA.

The update sits alongside recent Swiss sanctions-list changes. A 2 November notice covered the Taliban sanctions list, while a 3 November notice reported an amendment to the Nicaragua list also taking effect at 23:00. A 16 October update to the Venezuela ordinance took effect at 09:00 that day.

The Sudan amendments took effect on 3 November 2026 at 23:00.