Swiss Federal Department for Economic Affairs, Education and Research updates Annex 1 of Myanmar sanctions ordinance
Swiss financial intermediaries must freeze assets of newly listed Myanmar-sanctioned parties and report affected business relationships to SECO — effective 23:00 on 2 June 2026; SECO reporting does not discharge the separate GwG AML reporting obligation.
Change
On 1 June 2026, Switzerland's WBF/DEFR amended Annex 1 of the Myanmar Sanctions Ordinance (SR 946.231.157.5), effective 23:00 on 2 June 2026, requiring financial intermediaries to implement prohibitions, freeze assets, and report to SECO.
Why it matters
The amendment updates the SESAM database with changes to the list of sanctioned persons, companies, and organisations under the Myanmar regime. Financial intermediaries must immediately implement prohibitions and freeze identified assets. SECO reporting is mandatory but does not satisfy the separate AML obligation — where suspicion of money laundering cannot be dispelled, intermediaries must additionally report to the Money Laundering Reporting Office under Article 9 GwG.
Implications
- — Swiss financial intermediaries must check the updated SESAM database for newly listed Myanmar-sanctioned persons and entities, freeze any identified assets, and implement the Ordinance's prohibitions from 23:00 on 2 June 2026 — failure to implement constitutes non-compliance with the Myanmar Ordinance.
- — Swiss financial intermediaries must report affected business relationships to SECO and separately assess whether suspicion of money laundering requires a report to the Money Laundering Reporting Office under Article 9 GwG — the SECO report does not substitute for the GwG reporting obligation where suspicion cannot be dispelled.
Who is affected
- — Sanctions compliance teams at Swiss financial intermediaries with Myanmar-related business relationships
- — AML compliance officers at Swiss financial intermediaries assessing GwG reporting obligations
What to watch
- — 2 June 2026 at 23:00: amended Annex 1 enters into force — asset freeze and SECO reporting obligations apply from this time.