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.

  • As of May 2023, there were 8 persons subject to Swiss asset freezing orders linked to the misappropriation of state assets in 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. Sanctions on Tunisian individuals suspected of committing serious corruption expired in January 2021, as they reached their statutory maximum duration of ten years. [1]

Legal acts & useful links