Swiss Federal Supreme Court Confirms: Reasonable Suspicion is Enough to Freeze Assets

Sanctions decisions often have to be made under pressure, with incomplete information and significant legal consequences.

The Swiss Federal Supreme Court has now provided important guidance. In judgment 4A_537/2025 of April 28, 2026, it confirmed that a well-founded suspicion may be enough to trigger an asset freeze under Article 15 of the Ukraine Ordinance.

This gives financial intermediaries more clarity when they face difficult decisions. It also reminds companies that sanctions risk assessments must be precise, well documented and broad enough to capture indirect control relationships. The practical takeaway is simple: where concrete links to sanctioned persons exist, especially through beneficial ownership, family or economic connections, internal escalation processes need to work quickly and reliably.

Alexander Schwartz explains the ruling and its relevance for businesses in our latest article.