Denied Party Screening in Switzerland

Denied party screening in Switzerland means checking your customers, suppliers, and partners against sanctions and restricted party lists before you trade. Swiss companies sit in the middle of global supply chains. That means one screening pass against a single list is rarely enough. You need to check Swiss lists, and often US and EU lists too.

This guide explains who runs Swiss sanctions, which laws apply, and why lists from other countries reach into Swiss deals. It also covers the export control side, since goods and technology carry their own screening duties. If you want the wider picture first, start with our denied party screening hub.

Who administers sanctions in Switzerland

The State Secretariat for Economic Affairs, known as SECO, is the federal body in charge. SECO implements the sanctions that the Federal Council adopts. It publishes the official designation lists. It processes licence applications, grants exemptions, runs investigations, and prosecutes breaches.

SECO also handles export controls for dual-use and industrial goods. So one authority touches both sides of your screening work. That is different from the United States, where sanctions sit with OFAC and export controls sit with BIS. In Switzerland, SECO is your main point of contact for both.

The legal framework you screen against

Swiss screening duties come from a few core laws. Each one covers a different type of restriction. You need to know which one applies to your deal.

Law	What it covers
Embargo Act (EmbA, SR 946.231)	Legal basis for sanctions. Lets the Federal Council pass ordinances that freeze assets and ban dealings with named parties.
Goods Control Act (GCA)	Controls dual-use goods, specific military goods, and related technology. Sets licence rules for exports.
War Material Act	Governs war materiel. Sets separate rules for arms and military equipment.

The Embargo Act came into force on 1 January 2003. It is the foundation for every sanctions ordinance. Each ordinance targets a country or theme, such as Russia, Iran, North Korea, or Syria. The named parties in those ordinances are what you screen against.

UN sanctions, EU sanctions, and Swiss choices

Switzerland draws its sanctions from two main sources. It carries over United Nations Security Council measures. It also adopts European Union sanctions, in whole or in part.

Switzerland keeps full discretion over what it adopts. It usually mirrors EU designations, but each Swiss measure is its own legal act. After Russia invaded Ukraine in 2022, Swiss sanctions largely tracked the EU Russia programme. Even so, the timing and technical detail can differ from the EU sanctions lists. A name can appear on one list before the other. That gap is exactly why you screen more than one source.

The Swiss sanctions list

SECO maintains a consolidated list of the parties named across all Swiss ordinances. It is searchable and updated often. This list is your primary Swiss reference. But it is not the whole job, as the next section shows.

Why US and EU lists also matter for Swiss firms

A Swiss company can be fully clean under Swiss law and still hit a wall abroad. Foreign rules reach into Swiss deals through money, goods, and partners. Here is how.

• US dollar payments. If a transaction clears through the US financial system, US sanctions can apply. Most cross-border trade still touches USD at some point. That pulls OFAC lists into scope.
• US-origin goods and technology. If your product contains controlled US content, or was made with US technology, BIS export rules can follow it. That brings the BIS Entity List and related lists into your screening.
• EU counterparties. If your buyer, bank, or logistics partner is in the EU, they must comply with EU sanctions. A party the EU has listed can block your deal even when Switzerland has not listed them.
• Group and contract exposure. Many Swiss firms have US or EU parents, customers, or lenders. Those ties import foreign compliance duties by contract.

The practical takeaway is simple. Screen against Swiss lists first. Then check the US and EU lists that fit your exposure. To see how the US programme differs from Swiss rules, read our note on the OFAC SDN list.

Sanctions and export controls are not the same

Screening names is one duty. Screening goods is another. In Switzerland both can hit the same shipment.

Sanctions ban dealings with listed persons and entities. Export controls under the Goods Control Act ask a different question. They ask what the item is, where it goes, and how it will be used. Dual-use goods, meaning items with both civilian and military uses, often need a SECO licence. You apply for those licences through Elic, SECO’s electronic licensing platform.

So a single export can trigger a party check and a goods check at once. If you are unsure how these two tracks split, our guide on the difference between export controls and sanctions breaks it down. For the wider basics, see what export controls are.

How to run screening in a Swiss context

A good process is repeatable and documented. Here is a workable order for a Swiss trader.

1. Collect full party details. Get legal name, address, and ownership for every customer, supplier, and intermediary.
2. Screen against the Swiss SECO list. This is your baseline for Swiss law.
3. Add US and EU lists that match your exposure. Include OFAC, BIS, and the EU consolidated list where money, goods, or partners bring them in.
4. Check ownership and control. A party may be clean while its owner is listed. Apply the ownership test before you clear it.
5. Classify the goods. Decide if the item is dual-use or controlled, then check if a licence is needed.
6. Resolve any hit. Confirm whether a match is real or a false positive. Do not proceed on a live match.
7. Keep records. Save the list version, the date, and the outcome for every check.

Ownership matters more than people expect. Under US rules, an entity owned 50 percent or more by one or more listed parties is treated as listed too, even if it is not named. The EU applies a control-based test as well. Read more on the 50 percent rule so you do not clear a hidden party.

Handling false positives

Common names produce plenty of near matches. A match on name alone is not proof. Compare date of birth, address, and identifiers before you act. Document why you cleared or held the party. Our guide on resolving false positives shows the steps.

Penalties and reporting duties

Breaches carry real weight. Under the Embargo Act, intentional violations can bring custodial sentences of up to five years, together with fines that can reach CHF 1 million. Refusing to give SECO information or access can bring detention or fines up to CHF 100,000. Managers can face liability for breaches by staff under them.

The Embargo Act also sets duty of disclosure obligations. If you hold assets or handle dealings tied to a listed party, you may have to report them to SECO. Sanctions ordinances can add sector-specific reporting on top. Build these reports into your process so they are not missed.

Keeping evidence of screening

Screening only helps if you can prove you did it. Save the exact list version and date for each check. Save the search terms and the result. Save who reviewed a hit and what they decided. This is your audit trail if SECO or a foreign regulator asks. See our note on record keeping for denied party screening for what to retain.

Frequently Asked Questions

Does Switzerland follow EU sanctions automatically?

No. Switzerland decides case by case. It often adopts EU measures, and since 2022 it has closely tracked the EU on Russia. But each Swiss measure is a separate legal act, and timing can differ. Screen the Swiss list on its own terms.

Do I need to screen US lists if I only trade from Switzerland?

Often yes. If your payment clears in US dollars, or your goods contain US content, or a partner is US-linked, US rules can apply. Match the extra lists to your real exposure rather than screening everything blindly.

Which authority do I contact for a Swiss export licence?

SECO. Dual-use and industrial goods licences run through SECO’s Elic platform. War materiel follows a separate track under the War Material Act. Classify your goods first, then apply for the right licence type.

What counts as a denied party in Switzerland?

Any person or entity named in a Swiss sanctions ordinance, plus parties owned or controlled by them. Dealings with these parties are restricted or banned. For a plain start, see our denied party screening 101 guide.

Key Takeaways

Denied party screening in Switzerland starts with SECO and the Embargo Act, but it rarely ends there. Screen the Swiss list first, then add the US and EU lists that your money, goods, and partners pull into scope. Check ownership, classify your goods for export control, resolve hits with care, and keep clear records of every check. Do that consistently and you protect your business from Swiss and foreign enforcement alike. If you want help setting up a screening process that fits Swiss and cross-border rules, get in touch with our team.