Swiss anti-corruption sanctions

A special administrative legal regime allows the Swiss government to apply asset freezing orders via the Foreign Illicit Assets Act (FIAA) in cases involving politically exposed persons (PEPs) very quickly. Its purpose is to facilitate freezing, confiscation and restitution of assets held by foreign PEPs or their close associates which have lost power in the country of origin, and where there is reason to assume that those assets were misappropriated. This should give time the new authorities to file requests for mutual legal assistance aiming at recovering the funds.

The Federal Council issues ordinances and rulings to freeze the assets of foreign individuals to safeguard the interests of the country. Asset freezing orders allow Switzerland to act in the absence of suspicious transactions reported to the financial intelligence unit, freezing requests from other jurisdictions, or opening of criminal investigations.

Similarly to the EU and Canada, Switzerland imposed these special asset freezing orders on the former ruling elite subject to corruption allegations in Egypt, Tunisia and Ukraine.

Asset freezing orders on Egyptian individuals were lifted in December 2017, after the Swiss judicial authorities closed mutual legal assistance procedures on cases with potential links to assets frozen in Switzerland.

Asset freezes related to Tunisian individuals suspected of committing serious corruption expired in January 2021, as they reached their statutory maximum duration of ten years.

Eight Ukrainian individuals remained on the list at the start of 2023.  However, after May 2022, Switzerland commenced several confiscation proceedings with regard to the frozen assets (some linked to Yuriy Ivanyushchenko), totaling about EUR  139 million (CHF 130 million). According to the Swiss government, the commencement of confiscation proceedings has obviated the need for the asset freeze, and the 2014 Ordinance in connection with Ukrainian assets was terminated on 27 February 2023.

  • As of January 2024, there were 0 persons subject to Swiss asset freezing orders linked to the misappropriation of state assets.  

Legal acts & useful links

People sanctioned by the Swiss government: