Embargo law · lists · beneficial owners
A sanctions breach does not ask whether you knew.
Sanctions law leaves little room for excuses. Supplying a listed party is a breach – whether the name appeared on the order or two levels behind it.
Switzerland adopts sanctions under its Embargo Act, frequently in step with the EU. Companies operating internationally must also reckon with EU lists and US programmes that can bite without an obvious US connection.
For an SME the task is uncomfortable because it never finishes: lists change constantly, and so do ownership structures. A one-off check at contract signature is a start, not a process.
Where hits arise
- Not at the company name but at the beneficial owners behind it.
- At third-country parent companies that are listed themselves.
- At renamings that make a known structure unrecognisable.
- At intermediaries in countries neighbouring sanctioned states.
- At products with possible dual use, regardless of the customer.
A proportionate process
- Define scope
- Which partners are screened, against which lists, at what rhythm.
- Screen at onboarding
- Before the first order, with a documented result.
- Repeat
- Regularly and on triggers – ownership change, new listing, new country.
- Handle hits
- A procedure for suspected matches: check, document, decide, report where required.
- Keep evidence
- When you screened against which list – without that record the screening does not count.
How SCRM covers it
Screening date on the record
Every check with a timestamp, the list used and the result.
Ownership structure
Parent and beneficial owners as relationships, so screening starts in the right place.
Recall dates
Fixed cycles per risk class instead of a one-off at signature.
Trigger-based checks
Changes to structure or country prompt a fresh screening.
Frequently asked
Is screening the company name enough?
Rarely. Shareholdings and beneficial owners matter too. A company can be controlled by a listed person without being listed itself.
How often must we screen?
No fixed interval exists. Screening at onboarding and thereafter on a risk basis is usual – and always on a trigger.
What if there is a possible hit?
Do not ship until it is resolved, document the case and take professional advice where needed. Documenting the clarification matters as much as the outcome.
As of July 2026. Sanctions law changes at short notice. Not legal advice.