Following the conclusion of the nuclear agreement (Joint
Comprehensive Plan of Action, JCPOA), the Federal Council decided
on 11 November 2015 to conduct a total revision of the Ordinance on
Measures regarding the Islamic Republic of Iran (SR 9184.108.40.206,
Iran-Ordinance"; see the respective report in the
The revision that came into force on 17 January 2016 caused an
unintentional tightening of the export criteria for certain
dual-use goods bound for Iran. On 18 May 2016, the Swiss Federal
Council decided punctual amendments on certain aspects of the
Ordinance on Measures regarding the Islamic Republic. This involved
adapting the licensing criteria for trade in certain dual-use goods
(Art. 3 para 3-3ter Iran-Ordinance):
For dual-use goods listed in Annex 2
Section 2 of the Ordinance, Iran is no longer required to grant the
right to examine the end-use of the relevant goods.
The licensing procedure for these
goods is simplified in that a licence no longer has to be issued by
the interdepartmental export control group, but may be issued by
In cases where SECO has already
issued a licence for the export of the relevant goods, the
provision of serviced will be exempt from the licensing
The amendment of the Ordinance came into force at 6pm on 18 May.
In parallel to the Federal Council decision, the EAER amended
annexes 6 and 7 of the Ordinance on 17 May.2016. This reflects
recent changes to the EU's corresponding sanction list. Two
entries have been removed from Annex 7, and 23 entries in Annexes 6
and 7 have been amended.
Consequently, trade in these dual-use goods will again be
assessed according to the same criteria as applied before the vast
majority of sanctions against Iran were lifted in January of this
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