At 23:00 on 18 February 2026, the Federal Department of Economic Affairs, Education and Research (EAER) brought an emergency amendment to Annex 2 of the Ordinance of 25 May 2005 on measures against Sudan (SR 946.231.18) into force — adding the same seven names that the EU Council had listed twenty days earlier under Council Decision (CFSP) 2026/254 of 29 January 2026. Firms tracking Swiss Sudan exposure solely through a weekly EU CFSP reconciliation had those seven persons unblocked throughout that interval. Rescreening the entire third-party inventory against Annex 2 is this week’s task — not something to defer to the next scheduled KYC refresh.

Sudan is not subject to the same automatic-adoption presumption as Russia, where Switzerland largely mirrors EU measures in step. The Ordinance implements UN sanctions resolution 1591 (2005) and additionally incorporates EU measures going beyond it, as set out in Council Decision (CFSP) 2023/2135. “Incorporates,” however, does not mean “mirrors in real time.” Annex 2 is a distinct list maintained by the EAER under delegation from the Bundesrat by departmental ordinance. Three reference dates since February illustrate the mechanics: 18 February 2026 (EU listing 29 January, lag 20 days); 25 February 2026 (UN Committee decision 24 February, lag one day); 28 April 2026 (update with no traceable EU or UN source to date).

In parallel, OFAC maintains its own Sudan/Darfur list under Executive Order 14098. Designated there include Mohammad Hamdan Daglo Mousa (“Hemedti,” RSF) since 7 January 2025 and Abdel Fattah Al-Burhan (SAF), as well as a Colombian mercenary network designated in December 2025 and further RSF commanders involved in the siege of El Fasher designated in February 2026. None of these individuals appear automatically on Annex 2 — SECO does not carry over OFAC designations for Sudan. For treasury departments with exposure to USD correspondent banks, OFAC is a separate list track, not a source redundant to SECO.

Three action points for Monday.

First: rescreen the entire third-party inventory against the 28 April 2026 version of the list. Checking only new onboardings is insufficient: the freeze obligation under Art. 2 SR 946.231.18 takes effect from the date of entry into force and binds existing relationships as well.

Second: examine the data-feed contract with the screening provider. If the source mapped to Swiss Sudan measures is listed as “EU CFSP” or the consolidated UN register, that is a documentable compliance gap. The authoritative source is Annex 2; the reporting obligation under Art. 6 EmbG (SR 946.231) attaches to that list, not to an EU or OFAC mirror.

Third: recalibrate the synchronisation cadence. The February listing was published as urgent and took effect that same evening at 23:00 — a weekly sync does not close the twenty-day gap from January.

Separately, financial intermediaries remain subject to the independent obligation under Art. 9 GwG to file a suspicious-activity report with MROS where, following a freeze, grounds for suspicion within the meaning of Art. 6 GwG persist. The reporting obligation under the EmbG does not discharge this duty.

The source of the April update remains unresolved. No contemporaneous EU or UN listing can currently be matched one-to-one to 28 April; whether the additions represent autonomous Swiss designations will be clarified by the next SECO notice with accompanying statement of reasons. Pending that confirmation, it is advisable to classify the 28 April additions as potentially autonomous and to record the source classification accordingly in the screening log.