Swiss banks are occasionally visited by OFAC officials, even though the US sanctions imposed by the Office of Foreign Assets Control (OFAC) do not have legal validity in Switzerland. While some Swiss banks have direct contact with OFAC, others may not be aware of these interactions.
In recent years, the focus of these informal bilateral meetings has been on Russia sanctions, with Andrea Gacki being a key figure in implementing them. Banks active in asset management, such as UBS, Credit Suisse, and Julius Baer, are likely targets of these meetings. The informal meetings are arranged bilaterally between the banks and OFAC without involving official bodies like the State Secretariat for Economic Affairs (Seco) or the financial market regulator Finma.
Despite concerns about a lack of transparency in these direct interactions between OFAC and Swiss banks, cooperation between the two parties is generally viewed as constructive, especially when it comes to matters related to Russia sanctions. However, high-ranking OFAC personnel or demands for confidential data may require involvement from Finma or Seco.