Updated UN sanctions: SESAM amended on 7 September (cross-border guide)

The UN committee amended the sanctions lists on 7 September 2026. The SESAM database automatically updates the restrictive measures in Switzerland.
Context
In short
- Update of UN sanctions lists on 7 September 2026
- SESAM database automatically updated in Switzerland
- Immediate validity by federal ordinance of 4 March 2016
- Banks and businesses must verify compliance
Key facts
- What: Changes to the UN sanctions list (persons, companies, organizations)
- When: 7 September 2026
- Where: Bern (Swiss federal coordination)
- Who: UN Sanctions Committee and Federal Council
- Validity: Immediate in Switzerland via ordinance
Bern, 7 September 2026. The United Nations Sanctions Committee has modified the list of individuals, companies and organizations subject to sanctions. The SESAM database, the Swiss central international compliance system, has been updated accordingly. According to the official communication from the Federal Administration, the changes acquire immediate legal validity in Swiss territory.
The underlying mechanism dates back to 4 March 2016, when the Federal Council approved a decisive ordinance: the automatic transposition of the United Nations Security Council sanctions lists. This rule eliminates bureaucratic delays between the UN decision and implementation in Switzerland. No new federal decrees, parliamentary ratifications or further administrative steps are needed. The change to the UN list comes into force instantly, binding economic operators and financial institutions to comply.
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Operational details
Automatic transposition and practical implications
The Federal Council's decision of 4 March 2016 represents a paradigm shift in the management of sanctions in Switzerland. Rather than wait for Parliament to legislate on each new UN measure, the Swiss government decided to delegate the power to update the lists directly to the UN Security Council. This approach reflects Switzerland's commitment to the multilateral system and to the fight against the financing of terrorism and illicit activities.
The operational consequence is immediate: no Swiss bank, no commercial company, no economic operator can claim not to be aware of a UN sanction. The September 7, 2026 amendment is effective as of September 7, 2026. Anyone who continues to transact with a sanctioned entity after that date commits a serious violation and becomes liable to administrative and criminal sanctions.
Each credit institution must implement automatic screening systems that compare its customers and suppliers against the updated SESAM database. The checks must take place: (1) at the time the commercial relationship is established; (2) periodically (at least monthly or quarterly); (3) immediately, as soon as a change is made public. A passive periodic check is not enough. Compliance requires active diligence and documentation of audits.
What changes in the scope of sanctions
The UN list includes individuals, groups, businesses and international organizations believed to be linked to threats to international peace and security, terrorism, or weapons proliferation. The September 7, 2026 update changed this perimeter — although the official communication does not specify exactly which entities have been added or removed, every Swiss operator must assume that at least one change has occurred and act accordingly.
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Key points
Concrete procedures: how to verify compliance
Economic operators and financial institutions must perform three levels of control. First level: initial verification when opening an account, establishing a business relationship or signing a contract. The new customer must be checked against SESAM before any transaction takes place. Second level: recurring periodic control. Most Swiss banks implement automatic monthly or quarterly screening. Third level: immediate reporting and blocking. If a match emerges, the bank must immediately freeze the funds, warn the customer (in certain cases) and report to the State Secretariat for Economic Affairs (SECO) and the enforcement authorities.
Documentation of these checks is mandatory. Swiss supervisory authorities regularly inspect credit institutions to ensure compliance with compliance checks. A gap in verification — or blatant negligence — exposes the institution to significant administrative fines and, in extreme cases, to criminal prosecution for money laundering or violations of economic sanctions.
Where to find SESAM and updates
The SESAM database is managed by the Swiss Federal Administration and publicly accessible online. Economic operators, legal consultants, financial sector professionals and banks connect directly to the portal to download and consult the updated lists. Each change, such as that of September 7, 2026, is made available in real time.
Furthermore, the Federal Council and the State Secretariat for Economic Affairs issue official communications when important changes occur. Businesses that engage in international trade, manage foreign funds or have foreign clients must subscribe to automatic notifications from SESAM to be notified immediately of updates.
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Frequently Asked Questions
- What is SESAM and when was it introduced in Switzerland?
- SESAM is the official Swiss database containing the sanctions lists of the United Nations Security Council. It was established by the Federal Ordinance approved by the Federal Council on 4 March 2016. This ordinance allows the automatic implementation of UN sanctions in Switzerland, ensuring that any changes to the UN list acquire immediate legal validity in our legal system.
- How does an update like the one of September 7, 2026 come into effect?
- If the UN Sanctions Committee amends the list on 7 September 2026, the change is automatically reflected in the SESAM database and becomes immediately binding in Switzerland. No additional decrees or parliamentary ratifications are required. Validity is instant and mandatory for all economic operators.
- Who is obliged to verify compliance with SESAM?
- Banks, asset management companies, foreign trade operators, companies that manage international transactions, and any entity that has commercial or financial relations with foreigners must verify their customers, suppliers and partners against the updated UN lists. The checks must take place at the time of establishment of the relationship and periodically, at least monthly or quarterly.
- What are the consequences of a violation of UN sanctions?
- Not explicitly specified in the official communication. However, failure to comply with UN sanctions exposes the economic operator to significant administrative sanctions, criminal prosecution for money laundering and violation of federal ordinances, and stricter controls by Swiss supervisory authorities.
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