The case

Sonntagszeitung reported that Swiss banks are going to close the accounts held by Russians. It seems that the banks are not only going to implement EU sanctions, but US and UK sanctions as well even though these measures have not been applied at EU level.

Source: Sonntagszeitung 16 June 2024, p. 39

The commentary

Russians not resident either in Switzerland or the EU will no longer be able to open accounts and those who already hold accounts will have their accounts cancelled or their assets frozen.

According to the article published in the Sonntagszeitung, 23 privated banks have been targeted by FINMA and advised to part with their clients. Further, FINMA have confirmed that they have been carrying out on-the-spot inspections in order to establish whether the banks have the organizational capacity to comply with and implement the sanctions.

As the issue lies at the interface between financial market law and the Embargo Act, FINMA carried out the checks together with SECO. For some banks, “additional sanctions-specific audits were also commissioned by external audit firms”. FINMA added that the risk management obligations include not only the organisational measures for compliance with Swiss sanctions, but also the limitation of risks in connection with non-compliance with the circumvention of foreign sanctions, and confirmed that by doing so, this is not only about compliance with EU sanctions, but other sanctions, too.

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