What is Swiss sanctions screening?
Swiss sanctions screening checks customers, counterparties and payments against the individuals, companies, organisations and vessels Switzerland has sanctioned. Sanctions are imposed through Federal Council ordinances under the Embargo Act (EmbA) and administered by the State Secretariat for Economic Affairs (SECO). For listed parties, funds and economic resources are frozen, and you can't make any funds or economic resources available to them, directly or indirectly.
What is the SECO sanctions list?
It's SECO's overall list of everyone subject to Swiss sanctions, published through its SESAM sanctions database. Each sanctions programme is a separate ordinance, and the people and entities it covers sit in that ordinance's annexes. For example, Annex 8 of the Ordinance on Measures in connection with the Situation in Ukraine holds the Russia-related listings. Other ordinances cover Belarus, Iran, Syria, North Korea, the Taliban and ISIL (Da'esh) and Al-Qaida, among others.
Does the SECO list include UN and EU sanctions?
Yes. The Embargo Act lets Switzerland implement sanctions ordered by the United Nations, the OSCE or its most significant trading partners. UN Security Council sanctions are implemented as a matter of course. EU sanctions are adopted by Federal Council decision, wholly or partially and on Switzerland's own timeline. That's why the SECO list overlaps heavily with the EU list without being identical to it.
Who has to comply with Swiss sanctions?
Swiss sanctions are territorial. They bind companies operating in Switzerland and people living there, but generally not Swiss nationals abroad or the foreign subsidiaries of Swiss companies. In October 2024 the Federal Council declined to copy the EU rule requiring parent companies to ensure their non-EU subsidiaries don't undermine sanctions. A Swiss company that uses a foreign subsidiary to evade sanctions can still be prosecuted. Banks, asset managers, fiduciaries, commodity traders, insurers, and payment and crypto firms all screen against the SECO list.
What does FINMA expect from banks and financial intermediaries?
SECO enforces the sanctions, while FINMA supervises how financial institutions organise their sanctions compliance, including through on-site reviews at exposed institutions. When a list changes, FINMA publishes a notice calling on financial intermediaries to apply the measures, freeze the assets of newly listed parties and report affected business relationships to SECO. Reporting to SECO doesn't replace anti-money laundering duties. If a case raises suspicion, the Anti-Money Laundering Act (AMLA) requires further checks, and if the suspicion can't be cleared, a report to the Money Laundering Reporting Office Switzerland (MROS).
What are the penalties for breaching Swiss sanctions?
Wilful breaches are criminal offences under the Embargo Act, and serious cases carry up to five years in prison. Breaching reporting duties, such as the obligation to report frozen assets, can bring fines of up to CHF 100,000. SECO investigates and prosecutes most breaches and refers the most serious cases to the Office of the Attorney General of Switzerland.
Do I need the Swiss list if I already screen EU or UN lists?
Yes, if you operate in Switzerland. Swiss sanctions are implemented autonomously, so a party the EU has listed may not be listed in Switzerland yet, and Swiss law, not the EU list, decides what you must freeze. With the sources option, one request screens the SECO list together with OFAC, UN, UK, EU, Canadian and Australian lists, and each list in the response carries its own version details.
Is there an official Swiss sanctions list API?
No. SECO publishes the overall list as an XML file with an XSD specification, offers an Excel export of the full database and runs the SESAM search engine for manual lookups, but there's no screening API. SECO also notes that its search engine is only a support tool and shows no ownership or control links. Building your own means parsing the XML, tracking every change and matching names against every alias. Our API does that and returns scored matches against the current list version.
How often is the SECO list updated?
Whenever an ordinance's annex is amended, with no fixed schedule. Some UN listings, such as those under the Taliban ordinance, apply directly in Switzerland as soon as the UN committee makes them, and SECO then updates SESAM. In April 2026, for example, a UN change made on 13 April reached SESAM on 14 April. That's why pulling the list often matters: we check it every 15 minutes, and every response states the list version it used. Re-screen existing customers after each update, since amendments can add aliases.
How do I confirm a potential match?
Compare the name, aliases, date of birth, nationality and other identifiers with the listing, and check which ordinance and annex the entry comes from. If the same person or entity also appears on another list, use the extra identifiers in those entries to confirm. If it's the same party, freeze and report to SECO. If you still can't tell, don't proceed. SECO answers questions at [email protected].
What do I have to report, and to whom?
Anyone who holds or manages funds, or knows of economic resources, that must be presumed frozen has to report them to SECO without delay, even on reasonable suspicion rather than certainty. Reports go to SECO electronically on its form, preferably through PrivaSphere Secure Messaging. If a payment involves a listed party, block the amount and report it; the funds may then be returned to a sender who isn't sanctioned. Under the Ukraine Ordinance, holders also send SECO an annual declaration of all frozen assets as at 31 December, due by 15 February, and must consult SECO before releasing anything.
Does the freeze cover companies owned or controlled by listed persons?
Yes. The freeze applies by law to funds and economic resources owned or controlled, directly or indirectly, by listed persons. SECO treats an entity as owned once listed persons hold 50% or more, directly or indirectly, and generally adds up the holdings of several listed persons. Control is assessed against set criteria, and if any of them applies, the entity is deemed controlled unless shown otherwise. An unlisted subsidiary won't match on its own, so screen beneficial owners (UBOs) too.
How do I screen vessels against the Swiss list?
Screen them as vessels, not companies. Switzerland sanctions ships, mainly tankers in Russia's shadow fleet. In December 2025 alone it added 116, with comprehensive bans on buying, selling or providing services to them, plus asset freezes on companies that manage them. Ships are often renamed and reflagged, so the API screens vessels as their own subject type, matched by name and IMO number. Screen the owner and manager too, since links to listed companies won't show in the vessel record.
How fast is the API, and can I try it for free?
Average response time is about 200 ms, fast enough to screen during onboarding or before a payment is released. The batch endpoint screens up to 50 subjects per request, which suits re-screening your customer base after a SECO list update. One screening is one subject, new accounts get 100 free screenings, and paid plans start at $149 a month.