The WBF amended Anhang 8 of the March 2022 Russia/Ukraine ordinance (SR 946.231.176.72) on June 16 — the third Russia-Ukraine list update since April. If your compliance workflow runs on a weekly or bi-weekly SECO export rather than a live feed, the gap between each WBF amendment and your next scheduled refresh is now a documentable control deficiency. A daily pull or Fedlex change-notification webhook is no longer aspirational hygiene for any institution with Russian-nexus counterparties. And if the 20th package's MAC-clause implications are still unresolved in any of your transaction documents, this is a further prompt to close that analysis.

FINMA published the Sudan SR 946.231.18 Anhang 2 update on June 5. The pattern we documented in May — WBF lists trail EU listings by roughly twenty days — is running uninterrupted. Screening against the EU Consolidated List only will miss the WBF-specific Sudan entries until the gazette cycle catches up. Your screening SOP should reference both lists by name and confirm which version number is loaded.

The April amendment to the December 2025 Iran ordinance (Anhänge 12 and 14) is still appearing in compliance feeds. If you set up controls under the new Iran framework at year-end — as our December ordinance deep-dive recommended — verify your annex version numbers now. Anhänge 12 and 14 concern the list of sanctioned persons and entities. An April amendment that reaches your desk in July is not a late read; it is a gap in your monitoring process.

On June 17 — the most recent item in this week's sanctions stack — FINMA announced another annex amendment, this one to the Hamas/Palestinian Islamic Jihad sanctions ordinance of April 10, 2024 (SR 946.231.09). That brings confirmed May–June Swiss sanctions amendments to at least five across Russia, Sudan, ISIL/Al-Qaida, Iran, and the Hamas/Palestinian Islamic Jihad regime. If your compliance calendar treats SECO list monitoring as quarterly work, the 2026 amendment cadence has structurally outrun it. The question for your next compliance committee agenda: what is the actual refresh frequency of your screening tool, and who owns that SLA.

The consultation on the partial AMLO-FINMA revision closed three and a half weeks ago. The three clauses identified in our May analysis — which shift the beneficial-ownership presumption early in the customer-onboarding flow — drew the sharpest pushback from private-banking associations. When FINMA publishes its Erläuterungsbericht alongside the final revision, that document will be the more informative read: it will show exactly which industry objections FINMA absorbed and which it rejected. The ordinance text tells you what the rule is; the Erläuterungsbericht tells you why FINMA believes the rule is defensible. That distinction matters when you argue scope with an examiner.

Servatius von Tatzenberg's piece today maps the EFD working group through which the Swiss financial sector now deposits its regulatory cost complaints. The political logic is coherent: after three successive regulatory cycles — DORA, AI Act, successive FINMA revisions — the industry's aggregate cost argument finally found a formal home. The operational reality is less comfortable. A working group that documents costs does not suspend compliance obligations. DORA ICT-risk implementation, the forthcoming GwV-FINMA revision, and Anhang III KI-VO deadlines are not paused while the group convenes. Treat it as a long-game lobbying vehicle — which it is — and not as a compliance calendar modifier. The EFD announcement sets out the scope exclusions: ongoing parliamentary matters and bank-stability measures remain outside the group's mandate.

Switzerland's NUFG consultation is drawing public challenges to its exclusion of cobalt from covered raw materials. The stakes are structural: the EU Battery Regulation (2023/1542) explicitly requires cobalt supply-chain due diligence, and the CSDDD's broader value-chain obligations reach cobalt extraction via the mineral-resources sector scope. A NUFG without cobalt means every Swiss company in the battery-materials supply chain runs parallel due-diligence frameworks — NUFG-lite domestically, CSDDD in full for any EU customer contract. As we argued in May, CSDDD already binds Swiss exporters contractually regardless of what NUFG says. The cobalt gap creates a two-tier audit burden, not a safe harbour. Battery-sector in-house teams should be submitting Vernehmlassungsantworten if they have not already — the deadline is this summer.

Law.com's international edition runs a substantial piece today on the legal architecture invoked — and ignored — around the Greenland situation. The Swiss in-house angle is indirect but not trivial: commercial arbitration clauses naming Geneva or Zürich as seat rest partly on the assumption that the enforcing state's political neutrality is stable and internationally recognised. When a major power demonstrably asserts that territorial acquisition can override treaty frameworks, the premium attached to "neutral seat" clauses in long-term contracts with Arctic-corridor or US-adjacent infrastructure exposure warrants reassessment. This belongs in the geopolitical risk paragraph of the next board briefing, not only in the international law team's reading pile. See also our Investitionsprüfgesetz analysis on where screening risk now enters the term sheet.

Hunton Andrews Kurth becomes the latest international firm to shut its China mainland office; Hong Kong headcounts across foreign firms are also declining according to Law.com data this week. At the same time, India has opened its legal services market to foreign firms for the first time. For Swiss Rechtsabteilungen managing Asia-Pacific operations, these two signals together are a panel-review trigger: the firm that handled your China-nexus work in 2022 may no longer have a local presence, and India — long the credentialed-counsel gap in Swiss multinationals' Asian footprints — is now formally accessible. The geography of external legal advice in Asia is shifting faster than most law firm panel reviews get updated.

Hogan Lovells and Cadwalader completed a merger on July 1, 2026, creating Hogan Lovells Cadwalader — reported as the largest law firm merger in history, with over 3,200 lawyers. For Swiss Rechtsabteilungen with either firm on their panel, the operative question is immediate: any engagement letter, rate card, or data-handling commitment signed before July 1 is now with a different legal entity. The Global Legal Tech Alliance the two firms joined — focused on AI adoption standards, not shared contract-analysis infrastructure — makes the data question concrete rather than theoretical. Documents submitted under pre-merger instructions may be processed under AI tools whose data residency and training-exclusion scope your existing letter did not contemplate. Before the next matter opens, confirm in writing: whether your data-handling terms survive the entity change, and whether the merged firm's alliance commitments extend to pre-merger material. The Art. 47 BankG obligation follows the data; verify it follows the entity restructuring too.

FINMA announced in February that it will relocate its Zurich office from the city centre to Oerlikon. The stated rationale — lower cost per workstation — is secondary. Oerlikon is where tech and fintech-sector employment concentrates; the move positions FINMA closer to Zurich's tech-sector employment base — whether talent acquisition was an operative driver is not stated in the announcement, but the locational logic is visible. Moving toward the talent pool rather than requiring it to commute to the Paradeplatz orbit is a rational adjustment. The consequence for regulated institutions: inspection teams in technical areas will become more capable over time. Supervisory reviews on ICT risk, DORA operational resilience metrics, and crypto-asset controls deserve deeper preparation than has sometimes been necessary.