UNICORN PRIVATE Sanctions compliance in Switzerland: which rules apply and what companies must do
In short
Switzerland is not in the EU: sanctions apply through the Embargo Act and the ordinances of the Federal Council.
The State Secretariat for Economic Affairs (SECO) implements the sanctions and publishes the list of sanctioned persons and entities.
Companies in Switzerland must check the Swiss list, and often the EU, UK and US lists too, depending on their business.
Applicable rules and competent authorities
The Federal Act on the Implementation of International Sanctions (Embargo Act) is the legal basis. The Federal Council adopts an ordinance for each sanctions regime, and Switzerland decides whether and how to adopt EU sanctions.
The State Secretariat for Economic Affairs (SECO) is responsible for implementing the sanctions, publishes the list of sanctioned persons and entities, receives reports of frozen assets and grants exceptions. SECO also handles export licences for dual use goods under the Goods Control Act.
Practical duties for companies
- Do not make funds or economic resources available to persons and entities on the Swiss sanctions list.
- Screen clients, suppliers, owners and banks against the SECO list, and against foreign lists when your business is exposed to them.
- Report frozen assets to SECO as required by the ordinances.
- Check whether your goods need an export licence from SECO, including dual use goods.
- Keep records of the checks you carried out and of the decisions taken.
Fines and penalties
We do not show an amount for this list because we have not verified one. The penalties are set by the national law that applies to your company: read the official source and ask your legal advisor.
Official sources
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Frequently asked questions
Does Switzerland apply EU sanctions?
Switzerland is not bound by EU sanctions, but the Federal Council decides whether to adopt them. Many EU measures have been adopted through Swiss ordinances.
Who publishes the Swiss sanctions list?
The State Secretariat for Economic Affairs (SECO) publishes the list of persons and entities subject to Swiss sanctions.
Why do we not show a fine for Switzerland?
We have not verified an amount on the official texts, so we do not show one. The penalties are set by the Embargo Act: read the official source and ask your legal advisor.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.