On 5 January 2026, Switzerland imposed an immediate freeze on any assets held in Switzerland by former Venezuelan President Nicolás Maduro and the politically exposed persons (PEP) associated with him (see the press release here). This follows Nicolás Maduro’s capture by US forces. Members of the current Venezuelan government are not affected by this asset freeze.
The asset freeze is stipulated in the newly released Ordinance on the freezing of assets in connection with Venezuela (Venezuela Ordinance) (see here), which is based on the Federal Act on the Freezing and the Restitution of Illicit Assets held by Foreign PEP (Foreign Illicit Assets Act (FIAA)) (see here). The FIAA establishes an obligation to report and provide information on assets in Switzerland held by listed PEP. All persons and institutions in Switzerland are subject to this obligation and must immediately notify the Money Laundering Reporting Office Switzerland of these assets. Non-compliance with the asset freeze may result in a custodial sentence of up to three years, and violations of the obligation to report may lead to a fine of up to CHF 250,000.
The asset freeze imposed on Nicolás Maduro and his associates is a so-called “freeze for the purposes of mutual legal assistance,” which the Swiss Federal Council can implement immediately before or right after a political upheaval (Article 3, paragraph 2 of the FIAA). The purpose of the asset freeze is to enable any future mutual legal assistance proceedings. Should these proceedings reveal that the funds held in Switzerland were illicitly acquired, Switzerland will seek to use them for the benefit of the Venezuelan people. By implementing the freeze, any withdrawal of assets from Switzerland is currently prevented, giving Venezuela time to initiate investigations and proceedings accordingly. This approach does not indicate whether the Federal Council considers Nicolás Maduro’s removal from power itself lawful or a breach of international law, but merely secures the possibility of future redress, thus avoiding assets from being moved out of Switzerland.
The asset freeze under the Venezuela Ordinance will remain valid for four years — until 4 January 2030 — until further notice. Most importantly, the Venezuela Ordinance complements the existing Venezuela sanctions, which include further asset freezes and which are incorporated into the Ordinance on measures against Venezuela (see here). The Venezuela sanctions were implemented due to human rights violations and the irregularities around the 2018 presidential elections.
