As covered by Swiss media, the State secretary of economic
affairs (SECO) has denied an export of surveillance technology to
Turkey. According to official SECO statistics the denied export
contained surveillance equipment classified as 5A001.f2, described
in the revised annex of the Goods Control Ordinance (GCO) as:
Category 5 - telecommunications and information security 5A1
systems, equipment and components -5A001 telecommunication systems,
equipment, parts thereof and accessories --f) Equipment specially
designed for the interception or interference of mobile
communication and surveillance equipment as follows, as well as
specially designed parts thereof: ---2) surveillance equipment not
covered by category 5A001f1 , specially designed for extraction of
terminal identifier (e.g. IMSI, TMSI, or IMEI), from signalling or
other metadata transmitted over the air
This kind of technology, generally known as IMSI-Catcher allows
identification of mobile end-users within a specific area and
mobile network cell.
The Ordinance on export and placement of goods for internet- and
mobile communication surveillance defines a general license
requirement for the export of surveillance equipment, independently
of the country of destination. The ordinance does not only cover
the export of goods but also the export of technology and brokering
services. The SECO denied the export to Turkey based on Art.6 para
1(a) of the Ordinance, this means the SECO assumed that it is very
likely that the equipment would be misused by the end-user for the
purpose of retaliation measures.
Companies that are active in the field of information technology
and surveillance equipment should ensure that potential export
license requirements are identified as early as possible. A solid
compliance program could help to avoid unpleasant events at the day
of export or even violations of the law with potentially
MME Compliance AG supports customers with their analysis of
regulatory environment and implementation of a suitable compliance
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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