Two export credit agencies, one OECD rulebook, and two very different answers to the question of where your equipment was built.
Most U.S. exporters know one export credit agency: EXIM Bank. Most Swiss and European exporters know theirs. Very few people on either side have compared the two structures directly, and that matters more than it sounds, because in export finance, the agency you can reach is largely decided by where your goods are made rather than by where your buyer sits.
The common ground is the OECD Arrangement
EXIM Bank and SERV, Swiss Export Risk Insurance, both operate inside the OECD Arrangement on Officially Supported Export Credits. That sets the shared architecture of almost every medium-term buyer credit in the market: a minimum 15% cash payment from the buyer, a maximum of 85% of contract value financed, and repayment tenors set by country category and sector rather than by negotiation.
If you have worked with one agency, the shape of a transaction under the other will look familiar. The differences begin immediately after that.
Content: the rule that decides which agency your deal belongs to
EXIM Bank sets its level of support at the lesser of 85% of the value of eligible goods and services in the export contract, or 100% of the U.S. content within them. Foreign-origin goods can count toward eligible contract value if they ship from the United States, but goods that never ship from the U.S. are excluded. The practical effect is that U.S. content is a hard cap: at 70% U.S. content you finance 70%, and the buyer’s cash requirement rises to 30%.
SERV runs the test from the other direction. It works to a Swiss content requirement of 20%. Provided a fifth of the order value is Swiss, the transaction is eligible. SERV also sets no minimum on company size or order volume, so smaller tickets are not screened out before anyone looks at the deal.
Read the two side by side and the strategic point is hard to miss. A Swiss exporter assembling largely foreign-built equipment can still bring an export credit agency to the table. The identical bill of materials put to EXIM would cut the financing sharply, or remove it.
Cover: who carries the last 5%
This is the difference that matters most to lenders, and the one exporters almost never hear about.
EXIM’s medium-term guarantee to the lender is unconditional and transferable, covering the principal and accrued interest on the guaranteed loan. A bank holding EXIM paper is, for practical purposes, holding U.S. sovereign risk.
SERV is an insurer rather than a guarantor, so mitigating risk for the lender works differently. Its buyer credit insurance covers a financial institution’s claim against a foreign borrower up to a maximum cover ratio of 95%, across political, commercial, transfer, and force majeure risk. The lender retains the balance, and that residual affects pricing and, sometimes, whether a bank will hold the asset at all.
Which is why SERV’s refinancing guarantee exists. Issued to a refinancing institution, payable on first written demand and with a cover ratio of up to 100%, it always sits on top of buyer credit insurance or an assigned supplier credit policy rather than replacing it. Combine the two, and a European transaction reaches the bank-friendly position that EXIM delivers through a single instrument.
Why this belongs in a sourcing conversation
None of this is administrative detail. Export credit insurance and ECA-backed buyer credit are among the most effective tools available for de-risking business in emerging markets, but eligibility is decided by your supply chain rather than by your credit. An exporter with manufacturing on both sides of the Atlantic has a genuine choice of agency, and that choice moves the financed percentage, the buyer’s cash requirement and the cost of the facility. In global trade finance those are rarely rounding differences.
Bottom Line
SERV and EXIM Bank answer the same question in two different ways. EXIM ties the financing to American content and hands the lender an unconditional guarantee. SERV asks only for 20% Swiss content, covers up to 95%, and offers a separate guarantee to close the gap. Knowing which structure your bill of materials qualifies for is a real competitive advantage in international trade, and it is a decision worth making before the contract is signed rather than after.
Atrafin structures ECA-backed export financing solutions for capital goods exporters and their overseas customers, covering both U.S. and European export credit agency routes. If you are working out which agency a transaction belongs to, get in touch.