SECO

The State Secretariat for Economic Affairs (SECO) administers economic sanctions within Switzerland's federal economic-policy machinery. The Federal Council enacts compulsory measures through ordinances; the competent department can adapt their annexes. SECO handles specified supervision, reporting and authorisation functions. Responsibilities remain distributed: under the Ukraine ordinance, migration, civil aviation, customs and other authorities retain defined tasks.

Authority and practice

Articles 1 and 2 of the Embargo Act authorise measures implementing sanctions adopted by the United Nations, the OSCE or Switzerland's major trading partners to uphold international law, particularly human rights. EU sanctions do not become Swiss law automatically. The Federal Council decides whether and how to adopt them, and the Swiss ordinance determines the applicable obligations and exceptions.

On 28 February 2022, the Federal Council decided to adopt EU sanctions against Russia; the existing Ukraine ordinance was comprehensively revised on 4 March. Its measures include asset freezes, financial restrictions and controls on military, dual-use, industrial, energy and transport-related goods. Swiss adoption can differ in scope and timing. The official 22 May 2026 notice, for example, recorded listings from the EU's twentieth package while withholding seven third-country companies; further measures were adopted on 19 August. These are dated decisions, not a claim that Switzerland has adopted every later EU measure.

SECO's functions extend beyond advice and referrals. Article 14 of the Embargo Act makes it the prosecuting and adjudicating authority under administrative criminal law; the Attorney General may initiate an investigation at the competent administrative unit's request when the seriousness of the offence justifies it. Under the Ukraine ordinance, Article 16 requires specified asset reports to SECO and Article 15 provides defined authorisation powers, with consultation requirements. An authorisation must be located in the applicable provision, not inferred from SECO's general mandate.

Swiss implementation can extend a coalition's restrictions to assets and transactions within Swiss jurisdiction. That is the statecraft mechanism. It does not establish enforcement effectiveness or show that every Russian-linked asset is frozen. Designation, ownership or control, the affected transaction and the relevant exception each matter; a reported frozen-asset total is neither a measure of all Russian wealth nor a standalone measure of sanctions success.

An asset freeze restricts disposal and use without itself transferring ownership. Under Article 15 of the Ukraine ordinance, the asset-freeze test is linked to listed persons and specified ownership, control or agency relationships. Other restrictions can depend on Russian nationality, residence or establishment: Article 20 includes such criteria for deposits and financial services, subject to exceptions and possible authorisations. Nationality alone is therefore neither a universal freeze rule nor a universal exemption from sanctions.

The institutional and legal account was reviewed on 22 October 2026 against the Embargo Act as at 1 July 2023 and the French Ukraine ordinance consolidated as at 21 September 2026. The official English translation of the Act is informational and has no legal force; the French text was also checked. Transaction decisions require the operative article, current annexes, exceptions and any relevant authorisation.

See also

Switzerland · Embargo Act (Switzerland, 2002) · Asset freeze · Coalition coverage (the coverage problem) · Export-control licensing regime

Sources

1. Swiss Confederation, Federal Act of 22 March 2002 on the Implementation of International Sanctions, status 1 July 2023, particularly Articles 1-4 and 13-16; official English translation, informational only.
2. Swiss Federal Council, Ordinance of 4 March 2022 on measures connected with the situation in Ukraine, French text consolidated as at 21 September 2026, particularly Articles 1, 15, 16, 20, 31 and 32.
3. SECO, Measures connected with the situation in Ukraine, retrieved 22 October 2026.
4. Swiss Federal Department of Economic Affairs, Education and Research, Ukraine: Switzerland expands its sanctions lists, 22 May 2026.
5. Swiss Federal Council, Ukraine: Federal Council implements 20th package of sanctions in line with previous practice, 19 August 2026.
6. SECO, FAQ: Sanctions de la Suisse, retrieved 22 October 2026.
7. SECO, Mission und Organisationsstruktur, retrieved 22 October 2026; Swiss Federal Council, Rapport de gestion 1999, Departement de l'economie, section 2.2.1, page 98.