Embargo Act (Switzerland, 2002)

Switzerland's Embargo Act is the federal framework for implementing international sanctions originating with the United Nations, the OSCE or major trading partners. It supplies Swiss legal authority for measures adopted through implementing ordinances. It does not make foreign sanctions automatically applicable in Switzerland.

Institutional roles

The Federal Council decides whether and how Switzerland adopts a sanctions package. SECO implements and administers relevant ordinances, including information, licensing and enforcement functions allocated by law. The originating United Nations, European Union or partner measure remains distinct from the Swiss decision and ordinance.

SECO states that the Act does not provide a basis for independent Swiss sanctions. Article 1(1) links this statutory power to sanctions adopted by the specified international sources, while Article 1(2) expressly reserves Federal Council measures under Article 184(3) of the Constitution to safeguard the country's interests. The limit on the Embargo Act therefore does not establish the absence of every separate Swiss power. European Union measures are considered case by case, not copied automatically. [1, Article 1; 3, questions on autonomous sanctions and EU alignment]

The framework differs from autonomous statutes such as the Sanctions and Anti-Money Laundering Act (UK, 2018) and the Autonomous Sanctions Act (Australia, 2011). It also differs institutionally from the European Union's Article 215 TFEU and CFSP sanctions architecture.

Assessment

Every current claim should name the Federal Council decision, implementing ordinance, covered conduct, effective date, exception or licence and SECO guidance. Alignment with a European Union measure does not prove identical scope or timing. As at 30 July 2026, the Act remained in force. SECO's FAQ page, checked on 25 October 2026, explains adoption practice and links a separate interpretation guide dated 30 June 2026. That date belongs to the guide and should not be assigned to the FAQ page as a whole. [3]

Asset freezes, trade prohibitions, reporting and criminal penalties should be traced to the specific ordinance. A policy announcement is not itself the operative Swiss restriction.

Sources

1. Swiss Confederation, *Loi fédérale sur l’application de sanctions internationales*, SR 946.231, 22 March 2002, consolidated version dated 1 July 2023, Article 1, accessed 25 October 2026. French is an official-language text; the English translation is informational and has no legal force.
2. State Secretariat for Economic Affairs, Legal basis for sanctions (accessed 30 July 2026).
3. State Secretariat for Economic Affairs, *FAQ: Sanctions de la Suisse*, questions on autonomous sanctions and EU alignment, and the linked interpretation guide dated 30 June 2026, accessed 25 October 2026.Return 1
4. Swiss Confederation, SECO sanctions information (accessed 30 July 2026).