Switzerland Asset Freezes of Foreign Politically Exposed Persons

When a foreign government falls and its leaders are suspected of having looted state assets, the Swiss Federal Council can preventively freeze their assets held in Switzerland. Since 2016, these freezes are ordered under the Federal Act on the Freezing and the Restitution of Illicit Assets held by Foreign Politically Exposed Persons (Foreign Illicit Assets Act, FIAA; SR 196.1), which codified earlier freezes based directly on the Swiss constitution. The freezes support the criminal proceedings and mutual legal assistance requests of the origin countries, with the aim of eventually returning illicit funds.

Each freeze is enacted as a Federal Council ordinance with an annex naming the targeted politically exposed persons and their relatives and close associates. This dataset covers the ordinances issued under the FIAA:

• Venezuela (Nicolás Maduro and entourage, since January 2026)
• Syria (Bashar al-Assad and entourage, since March 2025)
• Ukraine (Viktor Yanukovych and entourage, 2016 to February 2023, when the freeze was superseded by administrative confiscation proceedings that keep the assets blocked)
• Tunisia (Zine El Abidine Ben Ali and entourage, 2016 to January 2021, when the ten-year statutory maximum duration was reached)
• Egypt (Hosni Mubarak and entourage, 2016 to December 2017, when the Federal Council lifted the freeze)

Persons de-listed by an amendment before the end of an ordinance are retained with the date of their removal. The freezes ordered against Libya (2011) and initially against Syria were folded into the corresponding SECO sanctions regimes and are covered there.

The named persons exist only in the ordinance annexes published on Fedlex, the Swiss federal law portal, not in any machine-readable list. The data is therefore maintained as a reviewed CSV file in the OpenSanctions repository, and the crawler monitors Fedlex for new ordinances and unreviewed amendments.