Swiss banks have been meeting with officials from the Office of Foreign Assets Control (OFAC) to discuss sanctions rules and interpretations, according to an anonymous observer. The informal meetings provide banks with a better understanding of OFAC’s objectives and help navigate complex sanction matters. While some Swiss banks have direct contact with OFAC, others may not be aware of these interactions.
In recent years, the focus has been on Russia sanctions, with Andrea Gacki being a key figure in implementing them. Swiss banks active in asset management, like UBS, Credit Suisse, and Julius Baer, are likely targets of these meetings. In cases of sensitive issues or high-ranking OFAC personnel or demands for confidential data, banks are expected to involve Finma or Seco. However, concerns about the lack of transparency in these direct interactions between OFAC and Swiss banks have been raised.
Despite the lack of legal validity of American sanctions in Switzerland, internationally operating companies must comply with them. OFAC enforces sanctions imposed by the US on states, companies, and individuals worldwide by freezing assets of sanctioned entities to cut them off from the American financial system. Swiss authorities do not receive official information about these bilateral discussions between OFAC and Swiss banks but sometimes receive reports from personal visits made by OFAC employees to Swiss banks.