Compliance guide
Sanctions lists: SECO, EU, UN and OFAC at a glance
Updated: · Leutrim Miftaraj, FLIORE · Editorial standards · Other languages: Deutsch · Français · Español
Short answer
For family offices in Switzerland, the sanctions of SECO are binding; in Germany and Austria, the financial sanctions of the EU. Sanctions of the UN Security Council feed into both. US sanctions of OFAC do not apply directly but become relevant for payments in US dollars, for US persons in the family and because banks apply them in their policies. Persons, companies and their owners are screened.
Which list applies where
| List | Binding for | Legal basis | Note |
|---|---|---|---|
| SECO | Switzerland | Embargo Act (EmbA) and Federal Council ordinances | Adopts many EU measures, but not automatically |
| EU | Germany, Austria | Council decisions and directly applicable EU regulations | Consolidated list of EU financial sanctions |
| UN | Members of the United Nations | Resolutions of the UN Security Council | Implemented via SECO or the EU |
| OFAC | USA, US persons | US law (including the SDN list) | Indirectly relevant through USD payments and bank policies |
Ownership and control count too
Sanctions do not only concern listed names. Under EU practice, the funds of a company are considered frozen if a listed person owns or controls more than 50 per cent of it. OFAC applies a 50 per cent rule under which the holdings of several listed persons are added together. For family offices with participations and co-investments this means: counterparties and their owners must be screened as well.
What to do in case of a hit
- Check the hit: do name, date of birth, nationality and other attributes match?
- Document false positives with reasons and close them.
- For a confirmed hit, allow no disposal of the assets.
- Report to the competent body: in Switzerland to SECO, in Germany for funds to the Deutsche Bundesbank, in Austria to the Oesterreichische Nationalbank.
- Also examine whether an anti-money laundering reporting obligation applies.
When screening takes place
When every person and every legal entity is onboarded, before larger payments to new counterparties, and continuously whenever the lists change. Continuous screening in particular is often underestimated: sanctions lists change frequently, sometimes several times a week. Screening once a year is therefore not enough.
Typical pitfalls
Three gaps recur in practice. First, screening only the family members and forgetting the companies, officers and counterparties of the structures. Second, closing false positives without a written reason, so that the same name is investigated again at the next update. Third, treating OFAC as irrelevant for a Swiss structure even though payments run in US dollars or a family member holds US citizenship. A short written screening policy that names the lists, the screened parties and the review cycle prevents all three.
In FLIORE
FLIORE checks persons daily against the SECO sanctions list and, through a connected data provider, against further lists such as the EU, UN and OFAC lists as well as PEP data. Hits are shown with a match score; assessment and decision are recorded in the audit trail.
At a glance
| Switzerland | SECO (Embargo Act) |
|---|---|
| Germany and Austria | EU financial sanctions, directly applicable |
| OFAC | Not directly binding, but relevant through USD and banks |
| Screening points | Onboarding, before payments to new counterparties, at every list change |
Terms on this page
- Audit trail
- An unalterable log that records who created, changed, approved or deleted which data and when.
Frequently asked questions
Does Switzerland adopt all EU sanctions?
No, not automatically. The Federal Council decides case by case and has adopted many EU measures, for example in connection with Russia. For Swiss family offices, the SECO list is authoritative.
Must a Swiss family office observe OFAC sanctions?
Not directly in legal terms, but often in practice: payments in US dollars run through US correspondent banks, and many banks prohibit business with OFAC-listed persons in their policies. US citizens in the family are personally subject to US law.
Is it enough to screen only the family members?
No. All persons and legal entities involved are screened – including companies, officers, beneficiaries and important counterparties such as buyers, sellers or co-investors.
How are name similarities handled?
With additional attributes such as date of birth, nationality and place of residence. A hit without a match on these attributes is closed as a false positive with reasons; the reasoning belongs in the file.
Sources
- SECO – Sanctions and embargoes
- EU Sanctions Map – consolidated EU sanctions
- OFAC – Office of Foreign Assets Control (US Treasury)
- Deutsche Bundesbank – financial sanctions
This page provides orientation and does not replace legal or tax advice. The cited legal sources in their applicable version are authoritative.
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