New customers, payments abroad, suppliers from third countries: in day-to-day business, Swiss companies keep coming across the EU sanctions list. Banks ask questions, business partners demand evidence, and management wants to know whether the company is properly set up.
This article explains what the EU sanctions list is, who appears on it and how it is maintained. It shows how sanctions screening works and how the EU list differs from the lists of SECO and OFAC. It also briefly mentions sanctioncheck.ch, a platform for screening and documentation.
In brief: What is the EU sanctions list?
The EU sanctions list is the consolidated compilation of persons, companies and organisations against which the European Union has imposed restrictive measures, above all financial sanctions such as the freezing of assets. The list changes continuously. Companies use it to check customers and suppliers so that risks can be recognised early. In Switzerland it does not apply automatically; the sanctions ordinances of the Federal Council, which SECO implements, are directly decisive.
Note: This article is for general information and is not legal advice. Every company remains responsible for its own compliance. For specific legal questions, consult a specialist.
Key points
- The EU sanctions list names persons, companies and organisations against which the EU has imposed restrictive measures.
- It does not apply automatically in Switzerland, but it can be relevant through business relationships, banks and Swiss practice.
- The EU, SECO and OFAC each maintain their own lists, which do not fully overlap.
- Good sanctions screening is regular, documented in a traceable way and covers several lists.
- Responsibility always remains with the company.
What is the EU sanctions list?
“EU sanctions list” usually means the consolidated list of persons and organisations against which the European Union has adopted restrictive measures. In English it is called “EU Financial Sanctions” or “Financial Sanctions Files” (FSF). The focus is on EU financial sanctions: assets are frozen, and neither funds nor economic resources may be made available to those concerned.
Strictly speaking, it is not a single list. The EU imposes sanctions in different frameworks: country-based, thematic or in implementation of UN decisions. In practice the entries are brought together and used jointly for screening.
Aim and purpose of sanctions
Sanctions are an instrument of foreign policy. They are meant to influence behaviour, for example violations of international law or serious human rights abuses, without using military means. Financial sanctions affect the economic room for manoeuvre of those concerned.
For companies this means that anyone doing business with listed persons can get into difficulties themselves. This is why screening business partners is important.
Who is on the EU sanctions list?
- Natural persons: for example officials, entrepreneurs or people in their circle
- Legal entities: such as trading companies, banks or industrial businesses
- Organisations and groups: for example terrorist associations or state-related institutions
An entry does not automatically mean that someone has been convicted of a criminal offence. It shows that the EU has imposed measures on the basis of a legal act and defined criteria.
How do EU sanctions come about?
Decision by the European Union
Sanctions arise within the framework of the Common Foreign and Security Policy. The Council of the EU adopts a decision, as a rule unanimously. For the economic measures, a regulation follows that applies directly in the member states. The Council of the EU describes the procedure on its page How the EU adopts and reviews sanctions.
The decision sets the political basis. The regulation sets out prohibitions and obligations. The listed persons and organisations appear in its annexes.
Publication and updates
The legal acts are published in the Official Journal of the EU. For day-to-day practice, the EU also provides consolidated data sets: the European Commission maintains the consolidated list of persons, groups and organisations subject to EU financial sanctions and updates it when necessary. The list reflects the legal acts published in the Official Journal of the EU (overview by the European Commission).
The list changes continuously. Entries are added, details are adjusted, and persons are removed, for example after reviews or court rulings. There is no fixed update cycle. A one-off check therefore loses its informative value over time.
What information does a list entry contain?
An entry is meant to allow identification that is as clear as possible. The level of detail varies by regime and by entry.
Individuals
- Name and known spellings, including in other scripts
- Date and place of birth
- Nationality and function
- Details of identity documents, where known
- Reasons for and date of the listing
Companies
- Company name and former or alternative names
- Registered office or address
- Registration details, where available
- Indications of links to other listed parties
- Reasons for the listing
Organisations
For groups, the list usually contains names, alias names, known locations and the reasons for the measure. The details are often less specific. This makes screening more demanding.
EU sanctions and Switzerland: Why is the list relevant for companies?
Switzerland is not part of the EU. EU sanctions therefore do not apply here automatically. Switzerland imposes sanctions on the basis of the Embargo Act by means of ordinances of the Federal Council. The State Secretariat for Economic Affairs (SECO) is responsible for enforcement and supervision.
According to SECO, the Federal Council decides case by case whether Switzerland adopts EU sanctions in full, in part or not at all; there is no automatic mechanism. Because the Federal Council must decide first, Swiss sanctions follow those of the EU with a delay. Responsibility for compliance with sanctions lies in principle with companies and other parties concerned (SECO: Frequently asked questions on sanctions, in German). Which Swiss sanctions ordinances apply is shown by SECO under Sanktionsverordnungen; individual persons and institutions can be found through the search for sanctions addressees.
Nevertheless, the EU sanctions list matters for Swiss companies for three reasons.
International business relationships
Anyone with customers in the EU, subsidiaries there or deliveries to the EU area can come into contact with EU law. According to the Council of the EU, EU sanctions regulations are binding on persons and companies within the EU. Banks and payment service providers in the EU may therefore withhold payments or request additional clarification.
Supplier and customer checks
Screening business partners: more and more companies carry out a customer check or supplier check before working together. This is not only about the direct counterparty but also about beneficial owners and affiliated companies. Banks, insurers and contractual partners increasingly require such checks.
Practical example: a Swiss machine manufacturer
A Swiss machine manufacturer receives an order from a third country. Before the contract is concluded, the customer company, its management and its beneficial owners are checked against the SECO, EU and OFAC lists.
The check produces no hit. The company documents the result and can show its bank and internal control functions that sanctions screening was carried out before the transaction was concluded. For export transactions, checking names does not replace checking the goods, the country of destination and the end use.
In many internationally active companies, such checks are part of a structured risk process.
Risk management
Sanctions screening is part of sound risk management and thus of compliance in Switzerland. It makes legal, financial and reputational risks visible at an early stage. Which obligations apply in an individual case depends on the sector, the activity and the business relationships. Which lists generally come into consideration for Swiss companies is shown in the article Which Sanctions Lists Matter for Swiss Companies?
Differences between the EU list, the SECO list and the OFAC list
The three lists come from different authorities and rest on different legal bases.
| Feature | EU | SECO | OFAC |
|---|---|---|---|
| Publisher | EU institutions | SECO, Switzerland | US Treasury Department |
| Scope | EU connection | Swiss connection | US connection |
| Well-known source | Consolidated EU financial sanctions | SECO sanctions register | SDN and other lists |
| For Swiss companies | Relevant depending on EU connection | Directly decisive | Relevant depending on US connection |
Important: The lists do not fully overlap. A person can be on one list without being on the others. For this reason, many companies screen against several lists.
Who should screen against the EU sanctions list regularly?
- Financial service providers
- Trustees
- Real estate companies
- Exporters
- Traders
- Consulting firms
- Compliance officers and legal departments with an international dimension
How does sanctions screening work?
Manual screening
In manual screening, names are searched directly in publicly accessible databases. For a small number of checks this is feasible. Multiple databases, spelling variants and documentation, however, increase the effort.
Automated screening
Automated screening, which is often called sanctions screening, compares names against several lists and can take different spellings into account. The result must be assessed by a qualified person. Software supports the screening but does not replace the company’s responsibility.
Documenting the results
- Date and time of the check
- Person or organisation checked, including the details used
- Lists taken into account and their status
- Result: no hit, possible hit or confirmed hit
- Assessment and reasons for possible hits
- Responsible person and, where applicable, approval
Which data sources are used for sanctions screening?
Companies often do not rely on a single list. Depending on the sector and the business model, several sources are taken into account.
- SECO sanctions list for Switzerland (SECO sanctions list explained)
- consolidated EU sanctions list
- OFAC lists of the US Treasury Department (OFAC sanctions list explained)
- sanctions lists of the United Nations (UN sanctions list explained)
- other national or sector-specific lists, for example the British UK Sanctions List
Because these sources do not fully overlap, many companies screen against several lists at the same time. Which sources are required or sensible must be determined by the company on the basis of its own risk profile.
Typical mistakes in sanctions screening
- Checking only one list
- A one-off check without repetition
- Checking only the direct counterparty
- Ignoring name variants
- Missing documentation
- Not assessing possible hits properly
- Unclear responsibilities
How does sanctioncheck.ch support companies?
sanctioncheck.ch is a platform with which companies can screen individuals, companies and organisations against the sanctions sources available on the platform at the time of the check. The platform is geared to business screening and its documentation. The PDF screening report shows the data status of the sources as stored at the time of the check, including, where available, that of the EU data. Sanctions screening is available on the home page, and the prices are publicly available.
- Screening against several lists
- consolidated presentation of results
- documentation of every check
- screening reports for internal files or enquiries
- clear and simple operation
The platform supports screening and documentation. The assessment of the results and responsibility for compliance with legal requirements remain with the company.
Why documented screening matters
Many companies carry out sanctions checks not only to minimise risk. Banks, auditors, business partners and internal control bodies can also ask for traceable evidence.
Documented screening creates transparency and helps to:
- demonstrate internal compliance processes
- answer enquiries more quickly
- carry out checks consistently
- recognise risks early
Besides the screening itself, documentation is therefore an important part of a professional compliance process.
Conclusion
The EU sanctions list is not automatically legally binding for Swiss companies, but in practice it often plays an important role: through business relationships with the EU, through requirements of banks and partners and through the link to Swiss sanctions measures. Anyone who screens customers, suppliers and business partners systematically reduces risks and creates clarity.
What matters is a clear process, screening against several lists, regular repetition and traceable documentation. The company remains responsible for its own compliance. Technical tools can reduce the effort but replace neither professional assessment nor, where applicable, legal advice.
Further topics
- Which Sanctions Lists Matter for Swiss Companies?
- What Is Sanctions Screening?
- SECO sanctions list explained
- OFAC sanctions list explained
- UN sanctions list explained
- UK sanctions list explained
- PEP list vs. sanctions list: the difference
Official sources
The information on procedure, publisher and Swiss practice is based on the following official sources (status of the source check: 11 October 2026):