Sanctions Screening in Switzerland: SECO Lists and PEP Checks

A Swiss sanctions check needs to answer two questions: does the supplied person or company match an official record, and what does the applicable restriction mean for the proposed activity? A list search supports the first question. The second needs the relevant ordinance, transaction facts and an accountable decision-maker.

For compliance teams choosing sanctions and PEP screening software in Switzerland, the practical challenge is connecting those checks to customer information, ownership evidence and review decisions. This guide explains that Swiss operating layer. Use the practical sanctions-screening guide for the wider process.

Start with the Swiss rules and your firm's scope

The Embargo Act provides the framework for Swiss sanctions measures. The relevant Federal Council ordinance and annexes determine the restriction. SECO explains that Switzerland implements UN Security Council sanctions, while the Federal Council decides case by case whether to adopt EU measures fully, partly or not at all. Check Swiss implementation rather than treating an EU announcement as the effective Swiss rule.¹

Map the contracting entity, activity, parties, payment route and relevant jurisdictions. Assess any applicable foreign obligations separately; a Swiss address does not settle every cross-border question. Record why each source is included in your screening policy.

Sanctions compliance and AML-regulated status are different questions. FINMA distinguishes SECO's sanctions-enforcement role from its own supervision of financial institutions' organisational controls and risk management.² Determine which AML requirements apply to the particular firm before assigning PEP and recordkeeping duties.

Use the SECO sanctions list and public search appropriately

SECO publishes a public search tool and a consolidated XML list. Its page also explains how to export the whole search database to Excel by leaving the search fields blank. SECO expressly warns that the search supports directly listed persons, companies and organisations and does not show possible ownership or control relationships.³

For an individual lookup, open the source record and capture its identifier, programme and available identity details. For a repeatable process, record when the data was retrieved, whether the import succeeded and which version was used. A successful file download is not proof that your screening system loaded the file correctly.

Choose a process for detecting source changes and repeating affected checks. Document the responsible team and what happens when an import or update fails. Set timing around applicable requirements and your operating model; this guide does not prescribe a universal daily screening schedule or a vendor update guarantee.

A sanctions list is one input. Trade, services, goods, destination or other restrictions can require checks beyond a named-party search.¹

Define the parties and events in scope

Build the screening population from the relationship you actually manage. Do not assume that checking a company name also checks its owners, or that a bank sees every party to your agreement.

Assign collection, candidate review, escalation and approval to named roles. A screening queue works better when an analyst knows what evidence is needed to resolve a case and who can decide the next action.

Investigate identity before deciding the consequence

Compare a candidate with the person or company supplied: names and aliases, date of birth or incorporation, nationality, address, registration information and other reliable identifiers where available. Distinguish a reliable mismatch from a missing field. A record without a birth date does not establish that two people are different.

Keep three conclusions separate:

1. Identity: whether the supplied party is the subject of the record.
2. Restriction: which measure, exception, authorisation or other condition applies to the activity.
3. Action: the required handling of the relationship, funds or service, with responsible approval.

A confirmed identity match does not mean every programme imposes an identical transaction ban. Equally, an unresolved case should not be cleared merely because the reviewer could not find enough information.

Assess ownership and control beyond the name result

An unlisted company is not automatically outside sanctions restrictions. SECO's interpretation guidance addresses ownership and control separately, including direct and indirect holdings, aggregated ownership and indicators of control. It is guidance rather than the binding ordinance.⁴

Obtain the relevant ownership and governance evidence, identify the applicable provision and refer uncertain structures to the responsible specialist. An AML beneficial-owner threshold, a shareholder percentage or a director's listing alone is not a complete sanctions conclusion. Screening supplied owners helps identify candidates; it does not discover an entire ownership chain or resolve control by itself.

Use the ownership and control explainer for the wider distinction, then apply the Swiss rule and facts to the particular case.

Apply Swiss PEP categories rather than a universal high-risk label

For firms within its scope, AMLA Article 2a defines foreign PEPs, Swiss domestic PEPs and PEPs in intergovernmental organisations or international sports federations. The Swiss domestic category concerns leading functions at national level and specified senior roles in state-owned enterprises of national significance. It also defines associated natural persons through recognisable family, personal or business connections.⁵

Article 6 distinguishes the risk treatment: relationships with foreign PEPs and their associated persons are always higher risk. Relationships with domestic PEPs, PEPs in intergovernmental organisations or international sports federations, and their associated persons are higher risk when combined with additional risk criteria.⁵

Review the person's identity, actual function, dates and relationship against the applicable category. Record the classification separately from sanctions status. A PEP result is not itself a sanctions designation or evidence of wrongdoing. The PEP screening guide explains the general review process; its UK-specific rules should not be substituted for Swiss rules.

Retain the decision and separate reporting routes

Keep the supplied identity, source record and retrieval date, screening configuration, evidence used, investigator, reasoning, approvals and final action together. If further work is needed, record the open question and owner rather than marking the case complete.

AMLA Article 7 requires in-scope financial intermediaries to retain relevant records for at least ten years after the relationship ends or transaction is completed. This is not a universal retention period for every Swiss business or every software log.⁵

SECO sanctions reporting and a suspicious-activity report to MROS are distinct assessments. MROS's typology report illustrates that a SECO report does not automatically require a MROS report, while AML clarification and reporting duties can still apply. Do not equate every unresolved name candidate with a reportable suspicion or an automatic asset freeze.⁶

For the technical reporting handoff, use the goAML integration guide. A screening decision record and a regulatory submission are different outputs.

Test sanctions screening software against your Swiss workflow

Ask vendors to demonstrate the tasks your team must complete, rather than comparing list counts alone.

Checklynx's sanctions screening software and PEP screening software support candidate review using grouped profiles and available structured identity and source context. That context helps analysts compare the intended subject with candidates and distinguish similarly named people. It does not replace ownership research, Swiss legal analysis or the firm's final decision.

Confirm the supported SECO coverage and configuration for your intended use. Run a representative pilot and compare both candidate quality and review effort. Use the software buyer guide to define acceptance criteria.

Three practical scenarios

These examples are hypothetical and illustrate review steps, not legal determinations about actual people or companies.

A corporate customer with a listed shareholder candidate

A Swiss firm receives ownership information for a new company. An owner produces a possible SECO match. The analyst first resolves identity, then supplies the ownership chain and governance evidence for the relevant Swiss assessment. The reviewer considers the ownership interests together with any evidence of control, even though the company itself has no name match. The team records the applicable restriction, conclusion and required action before approving the proposed activity.

A similar name with incomplete identifiers

An existing customer resembles a listed person, but the source record lacks a full birth date. The reviewer compares the available identifiers and seeks the information needed to resolve the uncertainty. Missing data is not recorded as a mismatch. The case retains either a supported non-match rationale or an open escalation, with the handling of any proposed activity assigned to the responsible team.

A customer takes a Swiss public role

A customer accepts a public appointment. The analyst checks the actual function against the Swiss statutory definition rather than classifying every cantonal or municipal office as a domestic PEP. The team documents the applicable category and additional risk factors, then applies the measures required for that relationship. Sanctions screening remains a separate assessment.

Frequently asked questions

Does checking EU sanctions also check Swiss sanctions?

Do not assume equivalence. Check the Swiss ordinance, annexes and supported SECO source, including the effective position for the activity. EU adoption is not automatic.¹

Is a clear SECO name search enough to approve a transaction?

The search does not resolve ownership or control. The transaction may also need assessment of goods, services, destination or other restrictions. Record which questions remain before approval.³¹

Must every Swiss company use the same PEP screening process?

Determine the firm's applicable AML framework and policy first. Do not apply a financial intermediary's requirements to every company, or treat all PEP categories as having identical consequences.

Can I use SECO's public search instead of screening software?

SECO's public search can support an individual list lookup. If your team needs to screen a customer population, repeat checks as data changes or share review records, assess how a maintained data integration or screening platform would support those tasks. Compare source coverage, review effort and the evidence you need to retain before choosing an approach.