# AMLR Art. 27 — UN-sanctioned customers > The TJPG Annex amendments to GwG Art. 1 and Art. 8 (adding EmbG coverage) and the revision of GwG Art. 22a Abs. 1 and 2 Bst. c have been in force since 1 October 2026. AMLR Art. 27 applies from 10 July 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.6 - Targeted financial sanctions related to terrorism and terrorist financing|FATF R.6]], [[FATF R.7 - Targeted financial sanctions related to proliferation|FATF R.7]] - **Swiss provisions:** [[GwG Art. 1 - Subject matter|GwG Art. 1]], [[GwG Art. 22a - EFD forwards data on terrorist|GwG Art. 22a]], [[EmbG]] - **Detailed citation:** EmbG; GwG Art. 1, 22a ## What it requires AMLR Art. 27 requires obliged entities, for customers subject to UN financial sanctions (or majority-controlled, individually or collectively, by such persons), to record the funds or assets they manage at the time the UN listing is made public, and every transaction attempted or carried out for that customer. This record-keeping duty runs only in the interim window between the UN listing becoming public and the corresponding EU targeted financial sanction taking effect. ## Swiss position GwG Art. 1 states the Act's subject matter as combating money laundering, terrorist financing and ensuring diligence in financial transactions; the TJPG Annex amendment, in force 1 October 2026, adds preventing breaches of Embargo Act (EmbG, SR 946.231) coercive measures. GwG Art. 8 requires organisational measures, including staff training and controls, for the same purposes, with the same EmbG addition from that date. GwG Art. 22a lets the Federal Department of Finance forward, via FINMA, data on persons another state has listed under UN Resolution 1373 for terrorism to supervised intermediaries and self-regulatory organisations; the 2026 revision broadens the SRO-forwarding limb from 'financial intermediaries' to 'persons'. ## Key divergences AMLR Art. 27 covers UN financial sanctions generally, not only terrorism, and imposes a specific interim record-keeping duty running automatically between a UN listing becoming public and the EU's own targeted financial sanction taking effect. Switzerland has no identified counterpart to that automatic-interim-application mechanism: it implements UN designations directly through EmbG ordinances rather than a downstream EU-style transposition step. GwG Art. 22a's UN Resolution 1373 data-forwarding chain concerns only terrorism-related listings, is a domestic distribution mechanism rather than a customer-level record-keeping duty, and its 2026 broadening to 'persons' reaches advisers rather than expanding sanctions scope. ## Effective dates The TJPG Annex amendments to GwG Art. 1 and Art. 8 (adding EmbG coverage) and the revision of GwG Art. 22a Abs. 1 and 2 Bst. c have been in force since 1 October 2026. AMLR Art. 27 applies from 10 July 2027. See [[Effective-dates timeline]]. ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 27 — English text (EUR-Lex, CELEX 32024R1624) > **Article 27** > *Temporary measures for customers subject to UN financial sanctions* > 1. In respect of customers that are subject to UN financial sanctions or that are controlled by natural or legal persons or entities subject to UN financial sanctions, or in which natural or legal persons or entities that are subject to UN financial sanctions have more than 50 % of the proprietary rights or majority interest, whether individually or collectively, obliged entities shall keep records of: > (a) the funds or other assets that they manage for the customer at the time when UN financial sanctions are made public; > (b) the transactions attempted by the customer; > (c) the transactions carried out for the customer. > 2. Obliged entities shall apply this Article between the time that UN financial sanctions are made public and the time of application of the relevant targeted financial sanctions in the Union. ## Sources - AMLR Art. 27 — CELEX 32024R1624 - GwG SR 955.0, Art. 1 - GwG SR 955.0, Art. 8 - GwG SR 955.0, Art. 22a - GwG rev. amendments to Art. 1, 8, 22a — sources/raw/tjpg.txt and sources/raw/gwg_rev_2025.txt - EmbG SR 946.231 (no primary source located)