The WBF amended Appendix 8 of the Russia ordinance on 16 June — the same annex your sanctions-screening workflow should be checking against continuously, not quarterly. The update arrives the same day we publish on Art. 12g of EU Regulation 833/2014, which embeds a no-re-export-to-Russia obligation in supply contracts touching EU counterparties. The connection is direct: Art. 12g clauses typically index to "persons on the applicable sanctions list," and the list just changed. If your contracts reference the Swiss register rather than the EU consolidated list, you have a drafting problem, not merely a compliance lag. See today's article for the clause language.

The earlier analysis of MAC clauses and the 20th package addressed the contractual trigger for material-adverse-change exits; this update is the operational trigger that runs on a different clock and keeps no appointments.

The Sudan ordinance was updated on 5 June — the same regime we covered in detail in our piece on the twenty-day lag between EU designation and Swiss reflection. The structural question has not changed: if your compliance workflow waits for the FINMA notification rather than running independently against the EU consolidated list, you are running late by design on every cycle. The frequency of Sudan updates this year suggests the regime is tracking active UK and EU designations on a rolling basis, not in batches.

Three FINMA sanctions notices in June — Russia (16th), Sudan (5th), and SR 946.231.09 on the 17th, covering the Verordnung vom 10. April 2024. Three in one month is operationally unremarkable, but it is exactly the right frequency to prompt a question your legal-ops team should already have answered: does your screening system pull these by automated API against the SECO consolidated register, or does someone read the FINMA RSS feed? The answer determines your exposure window every time an annex moves.

Today's piece by Casimir von Firn maps what Art. 50 of the EU AI Act requires by early August and why the obligation falls on deployers — the companies distributing AI-generated content into the EU — rather than on foundation-model providers. Swiss companies distributing AI outputs into EU markets are deployers under the Act regardless of where the model runs or who built it. The label duty attaches to the output, not the system.

The Swissinfo piece on AI at Europe's borders provides the concrete operational context: border agencies and law-enforcement bodies are already running AI outputs at scale, precisely the environment in which Art. 50's disclosure requirements carry the most weight and the least tolerance for non-compliance. If your company is selling or licensing AI outputs into that procurement space, the five-week window is not generous.

The second article today, also by Casimir von Firn, maps how Art. 12g of EU Regulation 833/2014 — the no-re-export-to-Russia clause — migrates into Swiss commercial paper through EU counterparty requirements. The obligation is not Bern's creation; it is imposed contractually by the EU-side party as a condition of sale, and it has been propagating through supply chains since the 2022 amendments accelerated the requirement. The question is not whether to include it — your EU counterparty will insist — but whether the clause as drafted correctly defines the restricted territory and references the right list. Combine this with today's Appendix 8 update above: the list the clause points to just changed.

Swiss voters rejected the revised CO2 law at the weekend. The political signal is clear. The compliance signal is more complicated, and in-house counsel should read it separately. Art. 964b OR — the climate reporting obligation for large Swiss companies — is not contingent on the CO2 law. It runs independently, its thresholds are fixed, and the reporting deadline does not move because a referendum went the other way. As we set out in May, the KIG path is a separate track from the statutory reporting obligation. The CO2 defeat does not change that analysis.

The more consequential effect runs through EU market access. CSRD, CS3D, and the EU taxonomy regulation impose climate disclosure obligations calibrated to EU political ambition — not to the result of a Swiss domestic vote. Swiss exporters with material EU revenues or EU subsidiaries are inside those obligations regardless of what happened on Sunday. Companies that read the ballot result as permission to slow their climate disclosure programs will find that their EU counterparties, lenders, and regulators disagree with that reading.

The consultation on the partial AMLO-FINMA revision closed three weeks ago. FINMA typically publishes a response document and the final revised text within three to six months of the consultation deadline. Our May analysis identified the three clauses that shift the burden on beneficial ownership transparency; the open question now is whether industry submissions moved FINMA's position on any of them. Watch the September–October window for the published text — and for whether FINMA addresses the volume of pushback it reportedly received on the documentation requirements for lower-risk client segments.

Hunton joins a growing list of international firms reducing or eliminating their Greater China presence. Law.com reports separately that Hong Kong's largest foreign firms continue to contract as the competitive landscape reorganises around local and mainland-connected practices. Two years ago this looked like cautious repositioning; the pace now looks structural. For Swiss clients whose international counsel panels were assembled when China coverage was a standard offering, the coverage map has moved and may need revisiting before it becomes a problem mid-matter.

A Law.com analysis runs through the international law framework — or its absence — around the Greenland discussions. For in-house counsel, the geopolitical outcome matters less than the risk-classification question: transactions with Arctic resource exposure, Greenlandic mining rights, or Nordic infrastructure now carry a sovereignty-risk dimension that standard political-risk matrix assessments do not capture. Check whether your investment treaty coverage addresses this before the project is underway rather than after the scenario crystallises.

Law.com documents five PE structures now reshaping international law firm capital. The read for in-house counsel is practical: a PE-backed firm operates under financial return expectations that a traditional partnership does not, and those expectations can shift matter selection, staffing decisions, and AFA appetite on a shorter horizon than partner tenure used to. If you are renegotiating panel arrangements with firms that have taken on external capital, the ownership structure and its exit timeline are now relevant context — not just practice rankings and rate cards.

Several major international firms have formed a joint AI tooling alliance. Shared infrastructure across competing firms raises questions that have not been fully resolved: whose data trains the models, how client confidentiality is maintained across the shared layer, and whether professional secrecy obligations under national bar rules travel with the data. Worth raising with your panel firms before the rollout notice arrives rather than after.

FINMA announced in February that its Zurich office moves from the city centre to Zurich-Oerlikon — lower cost per workstation, better working conditions, the usual rationale. For supervised institutions in the habit of convening at Lintheschergasse: update your logistics. The Berne headquarters is unaffected. A small operational note to close a day that was otherwise not small.