SECO Export Controls: Dual-Use Goods & Sanctions

The Swiss State Secretariat for Economic Affairs (SECO — Staatssekretariat fuer Wirtschaft) is responsible for implementing Switzerland’s export control regime and enforcing economic sanctions. Swiss companies exporting controlled goods — including dual-use items with civilian and military applications, war materiel, and certain technologies — must obtain SECO export permits. Switzerland’s sanctions regime aligns with UN Security Council sanctions and, selectively, with EU and US measures.

SECO’s Role in Export Controls

SECO is part of the Federal Department of Economic Affairs, Education and Research (EAER/WBF). In the export control domain, SECO:

• Issues export permits for dual-use goods and technologies (under the Goods Control Act — Gueterkontrollgesetz, GKG)
• Issues war materiel export licences (under the War Materiel Act — Kriegsmaterialgesetz, KMG) — in coordination with the Department of Foreign Affairs and Defence
• Enforces Swiss sanctions (under the Embargo Act — Embargogesetz, EmbG)
• Maintains the Swiss sanctions list — persons, entities, and vessels subject to asset freezes and transaction prohibitions
• Issues sanctions exception licences for humanitarian or other permitted activities

Dual-Use Goods: The Goods Control Act (GKG)

Dual-use goods are products and technologies that have both legitimate civilian uses and potential military or proliferation applications. Examples include:

• Electronics and semiconductors above certain performance specifications
• Chemical precursors
• Encryption and cybersecurity software
• Lasers, sensors, and optical equipment
• Machine tools and manufacturing equipment above specific tolerances

The Goods Control Act (GKG) and its implementing ordinance (GKV) list all controlled dual-use items in annexes based on the Wassenaar Arrangement, Nuclear Suppliers Group, Australia Group, and Missile Technology Control Regime (MTCR) control lists.

Export permit required: For controlled dual-use goods exported to non-EEA countries, an export permit from SECO is required. Switzerland is aligned with EU dual-use regulations (EU 2021/821) through its own parallel list.

Catch-all clause: Even for goods not explicitly listed, SECO can require a permit if the exporter knows or suspects the goods are intended for WMD-related end use.

War Materiel Exports (KMG)

War materiel (weapons, ammunition, explosives, military vehicles, etc.) requires a separate licence under the War Materiel Act. SECO issues licences in coordination with:

• Federal Department of Foreign Affairs (EDA)
• Federal Department of Defence (VBS)

Switzerland’s re-export debate: Swiss neutrality law prohibits Switzerland from allowing Swiss-origin war materiel to be re-exported to conflict parties by third countries without Swiss approval. This has been politically contentious regarding Ukrainian war materiel — Switzerland has maintained its re-export prohibition as a matter of neutrality policy.

Swiss Sanctions (Embargo Act — EmbG)

Switzerland implements sanctions through the Embargo Act (Embargogesetz). Swiss sanctions are adopted in response to:

• UN Security Council resolutions: Switzerland implements all UN mandatory sanctions
• EU autonomous sanctions: Switzerland has historically adopted EU sanctions on a case-by-case basis — it adopted EU sanctions against Russia following the 2022 invasion of Ukraine, including asset freezes on designated persons and entities
• US OFAC sanctions: Switzerland does not automatically adopt US unilateral sanctions, but Swiss banks apply OFAC-type compliance out of USD correspondent banking necessity

Current major sanctions programmes (2026):

• Russia / Belarus: extensive asset freezes, sector sanctions, import/export restrictions
• Iran: WMD-related restrictions
• North Korea: UN Security Council mandatory sanctions
• Syria, Libya, Sudan, Myanmar: various targeted measures
• Individual designations: terrorists, proliferators, corrupt officials

SECO Sanctions List

SECO maintains the Swiss sanctions list, searchable at seco.admin.ch. The list includes:

• Natural persons (with name, date of birth, nationality)
• Legal entities (companies, organisations)
• Vessels

Compliance requirement: Swiss companies must screen counterparties against the SECO sanctions list before transactions. Banks, financial intermediaries, and exporters are required by law to check and freeze assets of listed persons.

Asset freeze: When a designated person is identified, Swiss financial intermediaries must immediately freeze assets and report to SECO within five days.

Export Permit Application Process

Step 1 — Classify your goods: Determine whether your goods or technology fall within the Goods Control Ordinance (GKV) annexes. SECO provides a classification helpline.

Step 2 — Determine destination country: Some countries are lower-risk (EU, US, Japan, Australia) with simplified treatment; others require full case-by-case assessment (China, Russia, certain Middle Eastern and African countries).

Step 3 — Apply online: Export permit applications are submitted online via the SECO Extranet portal (serv-ch.com).

Step 4 — End-user certificate: For sensitive goods, SECO may require an End-User Certificate (EUC) from the importing entity — a declaration of the intended final use.

Step 5 — SECO review: SECO evaluates the application against the control lists, destination country, end user, and end use. Processing typically takes 2–6 weeks for standard applications; longer for complex or sensitive cases.

Fees: SECO export permit fees range from CHF 100–2,000 depending on type and value of goods.

SECO Staff Leasing and Placement Licences

SECO’s regulatory authority extends beyond export controls into the labour market. Any company providing staff leasing (Personalverleih) or placement services in Switzerland requires a SECO licence under the Employment Services Act (Arbeitsvermittlungsgesetz, AVG).

A Common Misconception

A persistent myth circulates among startups and foreign companies entering the Swiss market: that fewer than ten placement contracts per year exempts a company from the licensing requirement. This is false. The licence is required regardless of volume — a single placement contract triggers the obligation if staff leasing is conducted on a professional basis.

Licence Requirements

The application must include:

• Certified Commercial Register extract (not older than six months)
• Lease agreement for business premises, including a floor plan
• General terms and conditions (AGBs) for the placement/leasing service
• Written confirmation that no placement fees are charged to jobseekers
• Appointment of a responsible person who is Swiss-resident, holds relevant qualifications, and has clean criminal and debt records

Penalties

Operating without a SECO staff leasing licence carries fines of up to CHF 100’000 for the provider. The client company faces fines of up to CHF 40’000 if it knowingly engages an unlicensed provider.

Cross-Border Structures

A master service agreement (MSA) issued by a foreign parent entity — say, a US company — does not cover the Swiss subsidiary’s placement activities. The Swiss entity must hold its own SECO licence and issue its own contracts. Payments for Swiss-based services must flow directly to the authorised Swiss provider, not to a foreign parent that lacks Swiss authorisation.

Case Study: The Semiconductor Exporter That Did Not Check

A Zurich-based electronics distributor sold precision semiconductor components to customers across Europe and Asia. The components fell within the Wassenaar Arrangement control list (Category 3 — Electronics). For EU customers, the company relied on a General Export Authorisation. For a new customer in a Gulf state, the sales team processed the order without consulting the compliance officer — or checking the control list classification against the destination country.

SECO’s enforcement division discovered the export during a routine audit of the company’s export records. The components required an individual export permit, which had never been applied for. The company’s internal records showed no evidence of a classification check, no end-user certificate, and no compliance review of the transaction.

Outcome: SECO imposed an administrative penalty, confiscated the remaining inventory of the same component, and placed the company under enhanced monitoring for three years. The company’s CEO was personally warned that repeat violations would result in criminal prosecution under Art. 14 GKG (up to three years’ imprisonment). The total cost — legal fees, penalty, lost inventory, and business disruption — exceeded CHF 200’000.

The lesson: Export control compliance is not optional, and it is not something the sales team can self-assess. A single unchecked export of a listed component to a non-exempt destination can trigger enforcement action that affects the entire business.

Internal Compliance Programmes (ICP)

Swiss companies that regularly export controlled goods should establish an Internal Compliance Programme (ICP). While not legally mandatory for all exporters, SECO strongly recommends ICPs, and having one can streamline the permit process. An effective ICP includes:

• Management commitment: Senior management sign-off on export control compliance
• Designated compliance officer: A named individual responsible for export control matters
• Product classification procedures: Systematic review of whether goods fall under control lists
• Transaction screening: Automated or manual screening against sanctions lists and end-use red flags
• Record-keeping: Documentation of all export transactions, permit applications, and compliance checks (retained for at least 10 years)
• Training: Regular training for staff involved in export operations
• Audit procedures: Periodic internal review of compliance processes

Companies with a functioning ICP may benefit from faster SECO processing times and simplified permit procedures for repeat transactions.

Penalties for Non-Compliance

Violations of the Goods Control Act and Embargo Act carry:

• Criminal penalties: up to 3 years imprisonment or fines
• Administrative penalties: goods confiscation
• Reputational consequences: SECO publishes enforcement decisions

Switzerland enforces export controls — non-compliance is not merely a technical violation.

For a broader overview, see our guide to Industry-Specific Licences.

Frequently Asked Questions

Does Switzerland implement EU sanctions against Russia?

Yes. Switzerland adopted EU Russia sanctions packages in 2022 following the Ukraine invasion, including asset freezes on designated persons and entities, sector restrictions, and import/export bans on certain goods. Switzerland updates its sanctions list in step with EU additions.

Do Swiss sanctions apply to Swiss subsidiaries of foreign companies?

Swiss sanctions apply to all entities operating in Switzerland, including subsidiaries of foreign companies, and to Swiss nationals wherever located. Foreign subsidiaries of Swiss companies may also be covered depending on the sanction type.

How often should we screen against the SECO sanctions list?

Best practice is daily or continuous screening for financial institutions; at minimum before any new transaction for other businesses. SECO updates the list frequently, especially during active geopolitical events.

What is the catch-all clause and when does it apply?

The catch-all clause means that even if your goods are not on the control lists, you must apply for a SECO export permit if you know or have reason to suspect that the goods will be used for weapons of mass destruction (nuclear, chemical, biological) or their delivery systems. The obligation is triggered by the exporter’s knowledge or reasonable suspicion of the end use, not by the classification of the goods themselves.

Can SECO revoke an export permit after it has been issued?

Yes. SECO can revoke or suspend a previously issued export permit if circumstances change — for example, if new sanctions are adopted that affect the destination country or end user, or if SECO receives information suggesting the goods may be diverted. Exporters should verify that their permit remains valid at the time of shipment.

Do export controls apply to technology transfers and software, not just physical goods?

Yes. The Goods Control Act covers intangible transfers of technology, including technical data, software, and know-how related to controlled goods. Sending controlled technical specifications by email, uploading them to a cloud server accessible from abroad, or providing training on controlled technology to foreign nationals can all require an export permit.

What is the difference between SECO export permits and customs declarations?

A SECO export permit is a regulatory authorisation to export controlled goods, obtained before export. A customs declaration is the administrative filing at the border for all exported goods. The two are separate processes — having a customs clearance does not replace the need for a SECO export permit, and vice versa. Both are required for controlled goods.

Are there simplified procedures for exports within Europe?

Switzerland maintains General Export Authorisations (GEAs) for certain categories of dual-use goods exported to low-risk destinations, including most EU and EFTA countries. GEAs allow export without an individual permit application, provided the goods, destination, and end use meet the GEA conditions. Not all controlled goods qualify, and the exporter must still maintain records and verify end-use compliance.

How does Switzerland’s export control regime compare with the EU’s?

Switzerland aligns its dual-use control lists with EU Regulation 2021/821 and participates in the same multilateral export control regimes (Wassenaar, NSG, Australia Group, MTCR). The main differences are procedural — Switzerland has its own permit application process through SECO rather than through EU member state authorities — and Switzerland maintains its own sanctions regime, which overlaps substantially but not entirely with EU sanctions.

What should a company do if it discovers a past export control violation?

Contact SECO voluntarily. Self-disclosure of past violations, when accompanied by corrective measures, is treated more favourably than violations discovered through SECO’s own enforcement activities. Companies should also engage legal counsel experienced in Swiss export control law, document the violation thoroughly, and implement remedial measures to prevent recurrence.

Related services: Company formation Switzerland | FINMA licensing Switzerland | Swiss business licences | Due diligence Switzerland

For the official SECO sanctions list and export control guidance, see SECO export controls and sanctions page. The Goods Control Act (GKG) is published at Fedlex — GKG. For the Embargo Act, see Fedlex — EmbG.