On October 7, 2026, the Swiss Federal Council published a notice that the United Nations Iraq Sanctions Committee (the 1518 Committee) has amended the list of sanctioned persons and entities under the Ordinance on Economic Measures against the Republic of Iraq (SR 946.206), and that the Swiss SESAM sanctions database has been adjusted accordingly. The amendment removed LOGARCHEO S.A. (UN reference IQe.200), a company listed since April 26, 2004 and domiciled at Chemin du Carmel, 1661 Le Paquier-Montbarry, Switzerland, after the 1518 Committee delisted it on October 5, 2026.
Swiss banks, securities firms, insurers, payment institutions and fiduciaries that screen counterparties or hold assets under the Iraq asset freeze must immediately remove LOGARCHEO S.A. from their screening files and release any assets frozen solely on that listing, or keep a freeze the ordinance no longer requires, in breach of SR 946.206 and the Embargo Act (SR 946.231).
What did the UN 1518 Committee change, and why does it bind Swiss screeners immediately?
The 1518 Committee, the Security Council body that maintains the Iraq sanctions list, removed LOGARCHEO S.A. from its consolidated list on October 5, 2026, recorded in UN press release SC/16468. The entity had been listed since April 26, 2004. The Swiss Federal Council published its SESAM-update notice on October 7, 2026.
Under the Federal Council's ordinance of March 4, 2016 on the automatic adoption of UN Security Council sanctions lists, changes to those lists become immediately legally valid in Switzerland as soon as SESAM is updated. There is no separate Swiss transposition step: the moment SESAM reflects the committee's decision, the Iraq ordinance (SR 946.206) gives it domestic effect, and the SECO-administered asset freeze must be applied or lifted accordingly.
| Date | Event |
|---|---|
| April 26, 2004 | LOGARCHEO S.A. listed by the UN 1518 Committee (IQe.200) |
| March 4, 2016 | Federal Council ordinance on automatic adoption of UN sanctions lists |
| October 5, 2026 | 1518 Committee delists LOGARCHEO S.A. (SC/16468) |
| October 7, 2026 | Federal Council publishes SESAM update notice |
Who must update their Iraq screening files?
The update touches every Swiss financial intermediary and service provider that screens counterparties or holds assets under the Iraq programme: banks and securities firms that run counterparty screening against SR 946.206, insurers and payment institutions that apply the Iraq asset freeze through SESAM, and fiduciaries and corporate-service providers that may administer LOGARCHEO S.A. or other Iraq-programme vehicles.
Because LOGARCHEO S.A. is Swiss-domiciled in Le Paquier-Montbarry, fiduciaries and corporate agents that formed or administer the vehicle are directly in scope, alongside the screening teams of any institution that ever matched the name or the UN reference IQe.200.
What should compliance teams do?
The action is immediate. Because the 2016 automatic-adoption ordinance makes the UN delisting legally valid in Switzerland the moment SESAM is updated, there is no forward compliance date to plan against: the freeze on LOGARCHEO S.A. lacks a legal basis.
- Remove LOGARCHEO S.A. and the reference IQe.200 from all Iraq asset-freeze screening files and sanctions filters, including SESAM-fed watchlists.
- Identify and release any assets or accounts frozen solely on the LOGARCHEO S.A. listing, after confirming no other sanctions regime still covers the same assets.
- Re-screen counterparties previously blocked or escalated on the IQe.200 match to confirm whether the relationship can proceed.
- Update internal sanctions-list version logs and audit trails to record the October 5, 2026 UN delisting and the October 7, 2026 SESAM update.
- Verify that automated screening engines and vendor feeds have ingested the SESAM update, not only the UN consolidated list.
What is the risk of leaving a stale SESAM file?
A screening file that lags SESAM cuts both ways. Keeping LOGARCHEO S.A. on the freeze after the ordinance no longer requires it breaches SR 946.206 and the Embargo Act (SR 946.231), leaving assets blocked without legal basis. Failing to ingest the full SESAM update also risks the opposite error, leaving a person who remains listed unfrozen. Either way, a stale file creates legal and supervisory exposure under the Embargo Act.
Next steps: confirm your screening engine has ingested the October 7, 2026 SESAM update, document the LOGARCHEO S.A. delisting in your sanctions audit trail, and brief your front-office and fiduciary teams that the IQe.200 match no longer triggers a freeze. Obsidian tracks every SESAM amendment and UN 1518 Committee decision as they publish, so your screening files never drift from the official list.
