Iran sanctions snapback in Switzerland: key developments

I. Trade restrictions: The trade-related sanctions represent a return to a highly restrictive export control environment. They notably include export bans of:

• • dual-use goods and technology;
  • military equipment, unmanned aerial vehicles and rocket-related goods;
  • surveillance technologies;
  • raw metals and energy-sector goods;
  • crude oil and petroleum products; and
  • precious metals.

Only narrow exceptions and grandfathering clauses apply. Certain “particular dual-use items” may still be exported, but only with prior authorisation from the State Secretariat for Economic Affairs (SECO). The revised regime also introduces new reporting obligations subject to criminal penalties – particularly in relation to petrochemical products and transactions involving Iranian currency – and effectively withdraws export risk insurance coverage for Iran, save for narrow humanitarian carve-outs.

II. Financing and participation restrictions: The sanctions also impose sweeping financing and investment restrictions. Loans, credits, equity participations and joint ventures connected to Iran’s oil, gas and petrochemical sectors, armaments production and sensitive dual-use goods are broadly prohibited. Co-operation along liquefied natural gas (LNG) supply chains is likewise restricted. At the same time, Iranian individuals and entities are barred from acquiring participations, forming joint ventures or engaging in financing activities linked to nuclear, missile or other highly controlled programmes. Financing activities related to “particular dual-use items” remain permissible (subject to authorisation by SECO).

III. Money transfer and financial services restrictions: Money transfers to or from an Iranian person or organisation (notably, the Iranian state, individuals resident or domiciled in Iran, and legal entities or organisations with seat in Iran or controlled by the Iranian state) are now subject to layered regulatory thresholds:

• • payments exceeding CHF 10,000 must be reported to SECO within five working days after execution or receipt; and
  • payments exceeding CHF 50,000 require prior authorisation from SECO.

The report or request for authorisation must be made by: (i) the financial intermediary of the originator; or (ii) the beneficiary;  or (iii) (if the financial intermediary is not domiciled in Switzerland) the payment recipient or the originator. In addition, the sanctions largely prohibit banking relationships between Swiss and Iranian banks, including subsidiaries and joint ventures, with limited exemptions. New prohibitions also apply to dealings in certain Iranian government or government-guaranteed bonds and to insurance and reinsurance activities involving designated parties, further constraining permissible Iran-related financial activity from Switzerland.

IV. Asset freezes and financial restrictions: The sanctions impose comprehensive asset-freeze measures on designated Iranian individuals and entities, prohibiting the direct or indirect provision of funds, economic resources and certain financial messaging services to them. The asset freezes also entail reporting obligations and prohibitions on the provision of funds or economic resources to designated persons.

V. Other restrictions: The sanctions include further restrictive measures, including a ban on providing technical or maintenance services to Iranian-controlled cargo aircraft suspected of transporting prohibited goods, with narrow humanitarian and safety exceptions. They also impose entry and transit bans on designated Iranian individuals, with limited exceptions. The sanctions also prohibit the fulfilment of claims by Iranian or listed persons and entities where the underlying contracts or transactions are frustrated by existing or former Iran sanctions regimes.

Asset freezes in focus: far-reaching restrictions with limited exceptions

Asset freezes are among the most intrusive instruments under Swiss sanctions law. They directly affect bank accounts, shareholdings, participations in Swiss companies and receivables governed by Swiss law, often with immediate consequences for both targeted persons and third parties. The list of sanctioned individuals and entities is subject to ongoing amendments (most recently in April 2026).

So far, the scale of enforcement remains modest. According to figures released by SECO, Switzerland had frozen Iranian assets totalling CHF 13.5 million as of April 2026, a comparatively low figure set against sanctions regimes targeting other jurisdictions. SECO has attributed this to the fact that the international sanctions already in force for many years had substantially reduced financial ties with Iran well before the September 2025 snapback. SECO has also pointed out that Switzerland is not imposing autonomous sanctions of its own, but is implementing the reinstated UN and (in part) EU measures.

The revised regime imposes a comprehensive freeze of funds and economic resources belonging to, or controlled by, designated Iranian individuals and entities listed in the Ordinance annexes. In parallel, it is prohibited to make available funds or economic resources, directly or indirectly, to listed individuals or entities. The provision of specific payment and financial messaging services to designated parties is similarly banned.

For affected parties, the legal remedies are limited. Upon request and under strict conditions, SECO may grant exceptional authorisations, notably for:

• the performance of existing contracts;
• the satisfaction of claims based on arbitral awards or judicial or administrative decisions;
• the avoidance of hardship cases;
• the payment of fees associated with ship de-flagging;
• the financing of specific activities permitted elsewhere in the Ordinance;
• humanitarian or basic-needs activities;
• official activities of diplomatic or consular missions or international organisations enjoying privileges and immunities; and
• the safeguarding of Swiss interests.

Beyond that, limited exceptions apply for humanitarian purposes only. The transfer of funds is permissible if necessary for humanitarian activities or other activities aimed at meeting basic human needs, carried out by international or humanitarian organisations, NGOs and their employees. The same applies to funds necessary for humanitarian activities carried out by public authorities or by organisations and companies receiving federal funding for such activities.

Other than these narrowly-defined scenarios, the financial prohibitions are designed to prevent sanctioned persons and entities from accessing economic value altogether.

There are also extensive reporting obligations to ensure effective enforcement:

• any person or organisation that holds, manages or becomes aware of funds or economic resources likely subject to an asset freeze must immediately make a report to SECO;
• financial institutions must submit annual reports detailing the amounts held as of 31 December of the previous year; and
• credits made to frozen accounts must be reported without delay.

Failure to report relevant assets or relationships may trigger enforcement measures and even criminal liability – punishable by a fine of up to CHF 100,000. The reinstated sanctions therefore represent significantly heightened compliance and enforcement risks for financial institutions and intermediaries

Conclusion

The snapback has reset the legal and compliance landscape for Iran-related activities, with the ongoing conflict adding a further layer of urgency: sanctions lists and enforcement priorities are moving faster than usual, and yesterday’s compliant structure may not remain so tomorrow.

For companies, financial institutions and investors with any exposure, direct or indirect, to Iran, three priorities are immediate. First, existing contracts and banking relationships predating the snapback should be reviewed for continued lawfulness. Second, trade finance arrangements, activities along LNG  supply chains and joint venture structures should be reassessed against the newly-prohibited categories. Third, any pending payment or transfer should be checked against the CHF 10,000 reporting and CHF 50,000 authorisation thresholds.

Given the pace of change, screening should be built into ongoing compliance processes, and not treated as a one-time exercise. Careful legal analysis and continuous monitoring are no longer precautionary; they are the new baseline for operating in this space at all.

LALIVE’s sanctions and export control team regularly advises clients on Iran-related exposure, SECO authorisation requests and the design of compliant contractual and financial structures. Please do not hesitate to reach out to discuss the impact of these developments on your business.