Further to our earlier posts publishing the Administrative Penalties imposed by Switzerland's SECO, we are providing details of a further 13 penalties imposed.
The blog is grateful to SECO for providing anonymised copies of the penalty notices.
16. Final administrative decision, dated 18 March 2024 (I.36)
SECO was notified by Customs at Geneva Airport following the seizure of weapon parts imported from Russia.
SECO pend an investigation and determined that the parts were not for weapons intended for hunting or sport.
The importer was individual who had ordered the goods from a Russian manufacturer. This is the first instance of a fine imposed on individual by SECO for Russian sanctions breaches.
SECO assessed the breach as negligent rather than intentional, and imposed a fine of CHF 300, plus costs of CHF 360. The imported items were confiscated.
17. Administrative penalty dated 18 March 2024 (I.72)
This notice relates to the attempted export of 4 leather bags each valued at €370, with a total value of €1,480.
The goods were returned to seller.
The notice states that this was a repeat infraction by the company in question, with it having been the subject of proceedings that were dismissed on 19 December 2022.
The export was said to be result of human error during a busy time and SECO took the view that the breach was negligent and not intentional.
The company was fined CHF 1000 with costs of CHF 560.
18. Administrative penalty dated 23 May 2024 (I.75)
SECO's proceedings were commenced on 8 January 2024 and relates to an attempted export by a Russian national to Russia of luxury jewelry valued at CHF 14,100 and seized at Zurich airport.
The jewelry had been sold to that person with a VAT exemption on the basis that the person was a tourist. The invoice issued by the selling company referred to the individual as resident in the Russian Federation.
SECO accepted that the breach by the seller was negligent and not intentional, and imposed a fine of CHF 4,500, and costs of CHF 1260.
The Notice contains no indication of confiscation of the proceeds from the sale, but will be of interest for sellers of luxury goods to Russian nationals, especially where there is a reason to think that the goods would be taken to Russia.
19. Administrative penalty dated 23 May 2024 (I.91)
The investigation was started on 27 February 2024, following the shipment of 12 electric heating resistors valued at CHF 6,400 bound for Russia and stopped at Zurich airport.
SECO determined that the breach was not intentional, but a result of a negligent failure to understand which products codes were prohibited. The company was noted as having cooperated.
A fine of CHF 1,000 was imposed plus CHF 1,260 in costs.
20. Administrative penalty dated 5 June 2024 (I.80)
This is a short notice with substantial redactions. It relates to the attempted export of flowmeters and electric motors to Russia of uncertain value.
The company was fined CHF 700 plus costs of CHF 40.
21. Administrative penalty dated 17 June 2024 (I.84)
This Notice relates to the attempted export of prohibited goods to Russia, being spare parts for machine tools.
The goods were not confiscated but were released back to the exporter.
The company was fined CHF 500, plus costs of CHF 650.
22. Administrative penalty dated 9 September 2024 (I.90)
This Notice relates to prohibited imports of plastic packaging from Russia valued at c. €3,536. The goods had been donated to assist with medical research and had not been purchased.
SECO took the view the breach was negligent and not intentional and imposed a fine of CHF 500 plus costs of CHF 580.
23. Administrative penalty dated 9 October 2024 (I.94)
This relates to an attempted export referred by Swiss Customs to SECO. Seven different categories of goods were involved, six of which were prohibited from export. The goods were valued at more than CHF 15,000.
The lawful export was allowed to proceed and the others goods were all returned to the exporter rather than being confiscated.
The company had conducted google searches to determine whether the goods were subject to prohibitions, but these provided faulty answers. SECO determined the breach was negligent and not intentional and so fined the company CHF 5,000, plus costs of CHF 1,460.
24. Administrative penalty dated 18 December 2024 (I.101)
This Notice relates to an attempted export of satellite parts to Ukraine without a licence. SECO approved a retrospective licence application to allow the export to proceed but imposed a fine of CHF 1000 plus CHF 20 in costs.
Previously SECO had taken the view that it was not permissible to apply for retrospective licences.
25. Administrative penalty dated 5 November 2024 (I.93)
The Notice relates to the importation of prohibited goods valued at €22,650 reported to SECO by Swiss Customs. SECO commenced its investigation in July 2024. The goods in question were an electrical cabinet with customs code 8537.1000.
The importer had obtained erroneous advice that the goods had a non-prohibited customs code.
SECO prosecuted for negligent breach and imposed a fined CHF 5,000 plus CHF 850 in costs.
26. Administrative penalty dated 9 May 2025 (I.109)
This Notice relates to an import shipment from Russia seized at Basel Airport and referred to SECO consisting of clothing valued at CHF 28,689. These were imports prohibited under Switzerland's Russian sanctions.
SECO accepted evidence from senior company representatives that they were unaware of the existence of the prohibitions, and so SECO proceeded on the basis of a negligence, rather than an intentional, breach.
A fine of CHF 2000 plus CHF 300 in costs was imposed.
27. Administrative penalty dated 11 June 2025 (I.110)
This Notice relates to the attempted export to Russia of goods of uncertain value with classification codes 8544.4200 (insulated cables), 3917.4000 (plastic fittings) and 8481.8000 (valves and other fittings). The exporter is said to have applied for, and been granted, a licence after the event.
The company was fined CHF 800 plus CHF 20 in costs.
28. Administrative penalty dated 9 July 2025 (I. 114)
This Notice relates to the seizure of goods valued at CHF 11,739 bound for export to Russia, with no licence having been sought, and with product code 9027.5000 (instruments for physical or chemical analysis).
The company was fined CHF 1000 with CHF 20 in costs. The fine is described as having been for the failure to obtain a licence, and not for the attempted unlicensed export itself.
The Notice does not indicate whether the goods were returned to the exporter or confiscated.
Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.
