A/HRC/45/9/Add.1 law, including a component on the prohibition of human trafficking, sexual exploitation/abuse and gender-based violence, and international humanitarian law). The document also provides guidance on what should be understood as sufficient training in this domain. The federal authorities regularly report on the implementation of the Act by publishing annual reports, as required by article 37. This allows companies, the broader public and other interested actors to keep abreast of activities, updates and statistics pertaining to the implementation of the law. 45. Nevertheless, implementation has its challenges. The Act is based on the premise that companies will declare relevant activities, with the risk that some companies may not do so. Notably, the law does not contain a monitoring mechanism, thus limiting the means for detecting undeclared activities or ensuring that companies are complying with its provisions. Limited human resources within the competent authority for implementing the Act is also a considerable challenge. 46. Overall, however, the competent federal authority has made tangible progress in putting the Act into practice since it entered into force in 2015. The annual implementation reports indicate a gradual increase in the number of declarations made regarding private security services provided abroad, suggesting that companies are increasingly aware of their obligation to comply with the law. In 2018, 24 companies made 479 declarations to the federal authority,23 a large majority of which concerned the protection of persons and the guarding or surveillance of goods and properties in “complex environments”. Services for armed or security forces, such as operational or logistical support, and intelligence activities, were among other sizeable services declared. About half of the declared activities were concentrated in the Middle East and North Africa. 47. The review procedure appears to be conducted for a small number of declared activities. In 2018, 16 review procedures were launched for the 479 activities declared, resulting in seven prohibitions, all related to operations involving armed or security forces, with the remaining cases either pending or allowed to carry out the declared activity. 48. The June 2019 decision of the competent authority to prohibit a company from providing services in Saudi Arabia and the United Arab Emirates on the grounds that these services were incompatible with the foreign policy objectives of Switzerland 24 received significant attention and led some to question the scope of the Act. The company in question exported military training airplanes, used by pilots who would go on to fly fighter aircraft, 25 together with accompanying technical support services. While the export of military equipment is regulated under the Federal Act on War Material and the Federal Act on the Control of Dual-Use Goods, Specific Military Goods and Strategic Goods, related services such as maintenance and training also fall under the scope of the Federal Act on Private Security Services Provided Abroad, thus creating a certain overlap. Separate regimes are in place for obtaining the necessary authorizations, and a coordination mechanism is in place. In this case, the authorities found that the company had failed to comply with its obligation to declare its activities abroad, and reported the incident to the Office of the Attorney General, which reportedly dismissed the complaint. 26 Moreover, the company decided to legally challenge the prohibition of its activities, the first time that a business entity had contested a decision of the federal authorities implementing the Act. At the time of writing, the case was pending before the Federal Administrative Court. 49. Significantly, the case gave rise to questions about the implementation of the Act, with some parliamentarians requesting the Government to review its interpretation of the scope of the Act and to clarify the interplay with the federal regulation on arms exports.27 In 23 24 25 26 27 10 See www.eda.admin.ch/dam/eda/en/documents/aussenpolitik/sicherheitspolitik/taetigkeitsbericht2018_EN.pdf. See www.admin.ch/gov/en/start/documentation/media-releases.msg-id-75587.html. See www.pilatus-aircraft.com/en/fly/pc-21. See https://www.rts.ch/info/suisse/10962257-pilatus-n-a-pas-viole-la-loi-suisse-avec-ses-activites-aumoyen-orient.html. See www.parlament.ch/de/ratsbetrieb/suche-curia-vista/geschaeft?AffairId=20193991 and www.parlament.ch/de/ratsbetrieb/suche-curia-vista/geschaeft?AffairId=20194297.