Interim sanctions officers and export control officers: roles and deployment

Short answer: An interim sanctions officer or interim export control officer handles the day-to-day work of sanctions and export control compliance for a defined period: screening, classification, licence applications, counterparty checks and documentation. Companies use them for new sanctions packages, vacancies, backlogs or a new internal compliance programme. Accountability towards the authorities stays with management.

This guide is for heads of compliance, general counsel and heads of customs and trade in Switzerland and Germany. It explains the roles, when an interim assignment makes sense, how to set one up step by step and what differs between the two countries.

When companies need interim sanctions and export control capacity

Interim capacity is usually needed when the rules change faster than the team can implement them. On 23 July 2026, for example, the EU adopted its 21st sanctions package against Russia. Switzerland decides on each package separately and often implements it with a delay. For companies operating in both jurisdictions, that means checking twice and adjusting twice.

• New sanctions packages: new listings and trade restrictions require customers, suppliers and running contracts to be screened again at short notice.
• Vacancy: the only person with export control knowledge resigns, goes on parental leave or is off sick. Shipments still must not leave unchecked.
• Backlog: open screening hits, unclassified items in the material master or stalled licence applications pile up.
• Building or revising the compliance programme: after an internal audit, an acquisition or entry into new markets, processes, instructions and training need to be reset.

What to do in the first days after a new package is set out in Sanctions compliance: tasks, roles and capacity when new packages arrive.

Roles at a glance: sanctions officer, export control officer and trade compliance

The roles differ mainly in whether they check people and payments or goods and technology. The table maps typical tasks to profile and level.

Alpinum Solutions provides these profiles through staff leasing or freelancing, as an individual professional or a team, part-time or full-time. The service at a glance: interim sanctions compliance, trade compliance and export control professionals.

Six steps to set up the assignment

A clear brief decides whether the extra capacity makes a difference in the first week.

1. Define the scope: sanctions, export control or both? Which entities, countries and product groups are affected?
2. Take stock: open screening hits, unclassified items, pending applications, upcoming shipments and internal deadlines.
3. Set the profile: role, level, industry knowledge (for example engineering, technology or financial services), languages and workload (20–100%).
4. Choose the model: staff leasing if the professional works in your team and systems under your instructions; freelancing for a defined package, such as rewriting the sanctions policy.
5. Fix decision rights: who releases shipments, who decides on hits and exiting relationships, who reports to authorities? These decisions stay with the company.
6. Plan the handover: document classifications, review notes and open items so that the internal team can carry them on.

Roles and capacity: what interim professionals take on and what stays in-house

Interim professionals handle the operational work; decisions with external effect stay with management and the people the company has appointed internally.

• The professional can take on: screening and hit investigation, classification, preparing licence applications and queries to authorities, drafting policies and training, documentation and reporting.
• Stays in-house: overall accountability for sanctions and export control compliance, approval of critical shipments and business relationships, notifications and voluntary disclosures to authorities.
• Level by task: junior (0–2 years' experience) for screening under clear instructions, experienced (3–6 years) for independent hit review and classification, senior (7+ years) for programme design, edge cases and alignment with management and external counsel.

Selected profiles are usually available within 48 hours; the start date is agreed between the company and Alpinum. Under staff leasing, the client company holds the right to give professional instructions and the professional is integrated into your organisation. Under freelancing, the professional works independently within the agreed mandate. For larger backlogs, a small team with an experienced lead pays off; see Building a legal and compliance taskforce.

Switzerland and Germany: what differs

The tasks are similar in both countries. The legal bases, authorities and contracting entity differ.

Groups with entities in both countries therefore often need a professional who can compare Swiss and EU measures side by side. In Austria, assignments run as freelancing or as staff leasing through the German or Swiss entity.

Limits and risks

• No legal advice from Alpinum: Alpinum is not a law firm. Legal assessments, voluntary disclosures and proceedings before authorities are handled by the legal department or external counsel.
• Define accountability: overall accountability for sanctions and export control compliance stays with management. Whether a professional can take on a function designated to the authorities depends on the rules in each country; clarify this with the competent authority or your external counsel before the assignment and agree who signs.
• Check specialist knowledge: classification requires a technical understanding of the products. Test it in the interview with real examples from your range.
• Loss of knowledge: classifications and hit decisions must be documented in a traceable way, otherwise the work starts again after the assignment.
• Confidentiality: customer, supply and product data are sensitive. Set up personal access rights and a confidentiality agreement before day one.

Frequently asked questions about interim sanctions and export control officers

What does an interim sanctions officer do?

An interim sanctions officer runs day-to-day sanctions compliance for a defined period: maintaining the sanctions policy, steering the screening of customers, suppliers and payments, preparing decisions on hits and implementing new sanctions packages. They report to the head of compliance or to management. Decisions to exit business relationships and notifications to authorities remain with the company.

Can an export control officer be external?

Operational export control tasks such as classification, licence applications and checking shipments can be handled by an external professional, either integrated into your team through staff leasing or as a defined freelance mandate. Overall accountability and the release of critical shipments stay with management. Which function has to be formally designated should be clarified with the competent authority or your external counsel.

Staff leasing or freelancing for sanctions and export control?

Staff leasing fits when the professional works in your systems for several months, checks shipments on an ongoing basis and takes instructions from you, for example during a vacancy. Freelancing fits defined packages such as overhauling the compliance programme or classifying a product line. Both models work part-time or full-time, for individuals or teams.

What experience should the professional have?

Screening can often be done by a junior or experienced profile working to clear instructions. Classification requires experience with comparable goods and the control lists. For leading sanctions compliance or building a compliance programme, a senior profile with at least seven years' experience is advisable, ideally with both Swiss and EU measures.

How quickly can support start?

Selected profiles are usually available within 48 hours. The start date is agreed between the company and Alpinum and depends on availability, access rights and onboarding. With new sanctions packages, it pays to clarify need and profile as soon as a package is announced rather than after it enters into force.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in the DACH region. Describe the role, scope and timeline, and you will receive selected profiles for staff leasing or freelancing.

• Sanctions, trade compliance and export control: interim professionals
• Sanctions compliance: tasks, roles and capacity when new packages arrive
• Roles & practice areas: all guides on roles and specialisms
• Discuss your needs

Last updated: 10 November 2026.