SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
    Sanctions Lists and Watchlists Explained

    SECO's whole list still contains 1,522 targets Switzerland has de-listed

    The Swiss sanctions XML: 8,667 targets, 54,910 spelling variants, every programme traceable to the EU or UN, and de-listed records left in place.

    The Swiss sanctions file is the best-engineered of the major national lists and the easiest to ingest wrongly. SECO — the State Secretariat for Economic Affairs — publishes a single whole-list XML through the SESAM search system, covering every ordinance the Federal Council has made under the Embargo Act to give effect to UN and EU measures. The schema is properly normalised: names decompose into parts with order and type, each part carries spelling variants tagged by language and script, addresses reference a shared place table, and every target carries a modification history with enactment, publication and effective dates. What the schema also does is keep de-listed targets in the file. Of the 8,667 targets in the file dated 27 August 2026, 1,522 have de-listed as their most recent modification, which leaves roughly 7,145 people, companies and vessels actually under measures. Load the file without reading modification-type and you have quietly added fifteen hundred names Switzerland removed, some of them years ago. The second thing worth knowing: every one of the 30 programmes in the file traces to an EU or UN measure. Switzerland designates nobody on its own initiative.

    What this workflow covers

    SCOPE
    • 8,667 targets in the whole-list XML dated 27 August 2026: 4,647 individuals, 3,329 entities and 691 vessels.
    • 1,522 of those targets carry de-listed as their latest modification. The file records 8,667 listings, 8,978 amendments and 1,559 de-listings in total, with publication dates from 13 December 2012 to 28 August 2026.
    • 30 sanctions programmes across 68 programme elements — Belarus, Situation in Ukraine, Iran, Syria, North Korea, ISIL and Al-Qaida, Taliban and the rest — each tagged with an origin of EU, UN, or both. There is no Swiss-only programme in the file.
    • 54,910 spelling variants, tagged by language and script: 34,478 Cyrillic, 14,943 Latin and 5,230 Arabic. No other European list ships transliteration data at this depth.
    • Each target carries a foreign-identifier holding the originating reference — a UN committee code such as IQi.013, or the numeric EU identifier — so you can join a Swiss record to the EU or UN listing behind it.
    • Download: the whole-list XML from sesam.search.admin.ch, roughly 42 MB, alongside an XSD updated 3 November 2023 and value lists for countries, organisations, languages and scripts, with an Excel export on the search screen. The modification elements are the delta mechanism: each carries modification-type, enactment-date, publication-date and effective-date, so a single current file lets you reconstruct the list as it stood on any past day.
    • Ownership and control are missing by design. SECO states that the search shows directly sanctioned parties only and says nothing about entities they own, so a Swiss check has to be paired with ownership tracing.
    • The richness of the name data is itself a hazard: a single Belarusian official ships with Latin, Belarusian Cyrillic and Russian Cyrillic forms of each name part. So do the de-listed records, which look exactly like live ones until you read the modification type.
    • A hit means an asset freeze and, for most programmes, an entry and transit ban, reportable to SECO. Switzerland is one of the main jurisdictions on our coverage register; whoever supplies your Swiss data, the question worth asking them is how they handle the de-listed targets.

    Key statistics

    DATA
    Targets in the whole-list XML dated 27 August 2026
    8,667 (4,647 individuals, 3,329 entities, 691 vessels)
    Counted from the SECO whole-list XML
    Targets whose latest modification is de-listed
    1,522
    Counted from the SECO whole-list XML
    Spelling variants by script
    34,478 Cyrillic, 14,943 Latin, 5,230 Arabic
    Counted from the SECO whole-list XML

    Compliance glossary

    TERMS
    SECO
    The State Secretariat for Economic Affairs, the Swiss federal body that administers sanctions ordinances, publishes the consolidated list and receives freeze reports.
    Embargo Act
    The Swiss statute under which the Federal Council enacts coercive measures by ordinance, in order to give effect to sanctions decided by the UN, the OSCE or Switzerland's major trading partners.
    Modification type
    The attribute on each change record in the Swiss XML saying whether the target was listed, amended or de-listed on that date. Reading it is what separates the live population from the historical one.
    Spelling variant
    An alternative rendering of a name part, tagged in the Swiss schema with its language and script. It is machine-readable transliteration data rather than a free-text alias.

    Authoritative references

    SOURCES

    Frequently asked questions

    Q&A
    Q.01
    Does Switzerland automatically adopt EU sanctions?
    Not automatically, but in practice comprehensively. The Federal Council decides for each package and enacts it as an ordinance under the Embargo Act, which is why the Swiss list can lag an EU package by days or weeks. Every one of the 30 programmes in the current file originates with the EU or the UN; Switzerland maintains no autonomous designation programme of its own.
    Q.02
    Why does the Swiss file contain people who are no longer sanctioned?
    Because the whole list is a history, not a snapshot. Targets keep their record when a measure ends, and the removal is expressed as a modification of type de-listed rather than as a deletion. On 27 August 2026 that applied to 1,522 of 8,667 targets. Filter on the latest modification type before you match against anything.
    Q.03
    Where do I download the SECO sanctions list?
    From the SESAM search system at sesam.search.admin.ch, which serves the whole list as XML with a published XSD and separate value lists for countries, languages and scripts. The search screen also offers an Excel export of the full database if you leave the search fields empty. Both are free and unauthenticated.
    Q.04
    Is the SECO list the legally binding text?
    No. The annexes to the individual Federal Council ordinances are the operative law, and the consolidated file is a convenience built on them. That matters when a package has been adopted but the file has not yet regenerated: the ordinance binds you from its own entry into force, not from the moment SECO republishes.
    Q.05
    Do I need to screen Switzerland separately if I already screen the EU list?
    Yes, for a Swiss nexus. The populations overlap heavily but the timing does not, and Swiss ordinances occasionally implement a measure with a different scope. If you have a Swiss entity, Swiss counterparties or Swiss francs in the chain, the Swiss file is the one your regulator will ask about.
    Q.06
    What makes the Swiss name data useful for matching?
    The spelling variants. Each name part carries variants tagged with the source language and the script they are written in, so you get Cyrillic and Latin forms of the same patronymic as structured data rather than as a comma-separated alias blob. If you build transliteration rules, this file is the best free training material among the national lists.