Daily · Iran Sanctions & Market Infrastructure · August 18, 2026

Updated sanctions for Iran in Switzerland

FINMA published amendments to Annexes 12, 13, and 14 of the Ordinance on measures against the Islamic Republic of Iran on August 18. While the publication is current, the substantive decision was made on December 12, 2025. Businesses with Swiss operations must immediately assess their counterparts and transactions against these updated annexes to ensure they are not dealing with newly restricted entities or activities. Our read: This is an administrative update to existing sanctions that requires a fresh compliance sweep to avoid penalties.

New EU reporting for non-EU clearing

ESMA has launched a consultation regarding a proposed annual reporting framework under EMIR. This proposal specifically targets clearing members and clients who clear transactions through recognized third-country central counterparties (CCPs)—essentially clearing houses located outside the European Union. For businesses, this signifies a likely increase in operational overhead and data management requirements to meet new transparency standards. Our read: The industry should expect more rigorous oversight of cross-border clearing activity.

Technical shifts in US market operations

The SEC issued several approvals today that impact the plumbing of US financial markets. The National Securities Clearing Corporation (NSCC) has enhanced its Supplemental Liquidity Deposit Rules and Processes, which affects how liquidity is managed and deposited. Simultaneously, the Depository Trust Company (DTC) amended its Redemptions Service Guide and Operational Arrangements, altering which securities are eligible for DTC services.

Additionally, the New York Stock Exchange (NYSE) saw updates to its Listed Company Manual regarding Section 802.01C, and amendments to Rules 7.31, 7.35, and 7.35B were granted immediate effectiveness. Collectively, these changes impact how firms manage collateral, the eligibility of assets for redemption, and the requirements for companies listed on the NYSE. Our read: These updates streamline market infrastructure but require treasury and listing officers to update their internal operational playbooks.

This overview is informational, not legal or compliance advice. Consult your lawyer or compliance specialist on specific decisions.

Sources

This overview is based on official regulator publications for the period:

CH (1)

EU (1)

UK (3)

US (16)