Switzerland extends Russia sanctions to crypto platforms and the digital rouble

On August 19, the Swiss Federal Council decided to adopt further measures from the European Union’s 20th sanctions package against Russia. The measures took effect on August 20.

The financial measures prohibit the use of Russian platforms for transferring or exchanging cryptoassets. Switzerland has also prohibited support for the development of certain Russian cryptoassets, including the digital rouble. The Federal Council said the measures are intended to prevent alternative means of payment from being used to circumvent sanctions.

FINMA’s notice instructs financial intermediaries to implement the prohibitions, freeze the assets of sanctioned persons and report affected business relationships to the State Secretariat for Economic Affairs. It also stresses that a report to SECO does not replace the additional enquiries required under Switzerland’s Anti-Money Laundering Act when suspicious circumstances arise. If those suspicions cannot be resolved, the intermediary must report them to the Money Laundering Reporting Office Switzerland.

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Sanctions screening commonly begins with the legal names of a company, its directors and its beneficial owners. Those checks remain essential, but the Swiss measures address a different source of exposure: the platform or crypto rail through which value is transferred.

A business may produce no direct sanctions-list match while still using an affected platform, supporting a restricted asset or relying on counterparties and settlement routes that bring the relationship within scope. The relevant KYB evidence may therefore extend beyond legal identity and ownership to the business model, platforms used, supported assets, operating jurisdictions and role of third parties in custody, conversion or settlement.

This is particularly important for VASPs, fintechs and payment providers. If onboarding does not capture how a customer moves or exchanges cryptoassets, the firm may have little structured information with which to apply an infrastructure-level prohibition later.

The immediate effective date also creates a monitoring problem for existing relationships. Re-screening customer and UBO names may return exactly the same result as before, even though the permissibility or risk of the relationship has changed. A sanctions update of this kind should feed into a scoped continuous-monitoring workflow: identify the potentially affected population, request the missing operational evidence, reassess risk and retain the rationale behind each outcome.

FINMA’s AML reminder adds a second layer. Implementing a sanctions prohibition or making a report to SECO may address the sanctions requirement, but suspicious circumstances can still require further enquiries and a separate reporting assessment. The case record needs to show which exposure was identified, what was investigated and how the final decision was reached.

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