Export-control Policy

Why this matters

brückenbauer GmbH operates at the intersection of electronics, semiconductors, sensors, micro-cameras, power electronics and aerospace-adjacent technologies. Several of these categories can fall under dual-use regulations, export-control regimes, and international sanctions. Compliance is not optional and not a footnote in our work — it is a precondition for engagement.

We will never knowingly facilitate a transaction that violates Swiss, EU, US, UK or UN export-control or sanctions law.

Our 5-step compliance gate

Before any client engagement is launched, before any supplier or buyer is introduced, and before any commercial document is signed, we complete and document the following:

Step 1 · Client KYC

Identity verification of the client entity, beneficial owners (≥ 25% ownership or control), and authorised signatory. Public registry checks and supporting documentation.

Step 2 · End-user check

Identification of the actual end-user of the technology, equipment or service. A written end-use declaration signed by the client and, where appropriate, the end-user.

Step 3 · Product classification

Where physical or digital deliverables are involved, classification under:

• Harmonised System (HS) code
• EU dual-use list (Annex I of Regulation (EU) 2021/821)
• US ECCN (Export Control Classification Number) where US-origin items are involved
• Swiss Güterkontrollverordnung (GKV) and military goods list where applicable

Step 4 · Sanctions screening

Screening of all parties (client, supplier, end-user, intermediaries) against the consolidated lists of:

• Swiss SECO sanctions
• EU Consolidated Financial Sanctions List
• UK OFSI
• US OFAC SDN and consolidated lists
• United Nations Security Council sanctions

Step 5 · Written go / no-go

A documented internal decision — go / no-go / conditional go — signed by an authorised principal of brückenbauer GmbH before the engagement proceeds. Where required, application is made for an export licence with the competent Swiss authority before any shipment or signed contract.

Either party may veto

In every engagement involving our strategic alliance partner TSARA Group, both brückenbauer GmbH and TSARA Group hold an unconditional veto on compliance grounds. Either party may decline, pause or terminate an engagement at any time if compliance risk is identified, without consequence to the relationship between the parties.

Sectors we approach with particular care

• Aerospace and defence-adjacent — components, sensors, cameras, materials with potential dual-use applications
• Advanced semiconductors — items potentially captured by US 10/7 and EU equivalent restrictions
• Power electronics for restricted end-uses — applications in energy, transport or controlled industrial sectors
• Imaging and surveillance — items potentially captured by EU dual-use category 6.A.3 and similar

For these categories, the compliance gate above is applied with heightened scrutiny.

Sanctioned countries and parties

brückenbauer GmbH does not undertake engagements with:

• Parties listed on EU, US, UK, Swiss SECO or UN sanctions lists
• End-users in jurisdictions subject to comprehensive sanctions
• Transactions involving prohibited end-uses (e.g. WMD-related, military end-users where prohibited)

Sanctions positions are subject to change and we monitor authoritative sources continuously.

Documentation and audit trail

All compliance documentation — KYC files, end-use declarations, classification opinions, screening results, internal go / no-go decisions — is retained for the duration of the engagement plus a minimum of 10 years, in line with Swiss recordkeeping requirements and applicable EU and US guidance.

Reporting concerns

If you have reason to believe a brückenbauer GmbH engagement may involve a compliance breach, please contact us directly at kontakt@brueckenbauer-gmbh.ch. Reports are reviewed promptly and confidentially.