Between April and June 2026, five FINMA sanctions notices have been independently verified: Russia/Belarus (Anhang 8 of SR 946.231.176.72, 16 June), Sudan (Anhang 2 of SR 946.231.18, 5 June), ISIL/Al-Qaida (SR 946.231.08, May), Iran (Anhänge 12 and 14 of SR 946.231.143.6, April), and Taliban (SR 946.231.07, April). None is individually surprising. Together they illustrate why monthly batch screening is structurally too slow: between two runs, the list may have moved three times across three ordinances. The deal-execution consequence — what happens when a counterparty appears on a new list between signing and closing — is addressed in today's SPA article below.

Published today: Dr. iur. Servatius von Tatzenberg on FINMA elevating its liquidity and concentration risk circular to ordinance level. The step converts supervisory guidance — which permitted proportionate deviation — into directly enforceable norms. Institutions that relied on the circular's flexibility to justify current practices need to check whether those practices survive the ordinance's actual text. This is part of a broader 2026 pattern: Swiss financial supervision is hardening soft instruments across the board. The question for each institution is the same — which parts of your compliance framework rested on guidance rather than rules? See the Banking Act Botschaft context from May here.

Also published today: Dr. iur. Servatius von Tatzenberg on the procedural collision between the Fundamental Rights Impact Assessment under Art. 27 KI-VO and the Data Protection Impact Assessment under Art. 35 DSGVO. Both are mandatory for certain high-risk AI deployments. Neither regulation specifies how to run them together. Von Tatzenberg maps where one assessment can satisfy both obligations and where the requirements diverge. With the first KI-VO operator obligations arriving in August, this is the question that will otherwise get answered by auditors after the first enforcement action. The Anhang III deferral timeline is here.

Third article out today: Casimir von Firn on the MAC clause that deal documentation rarely contains — a provision addressing what happens when a counterparty, seller affiliate, or key target entity appears on a new sanctions list between signing and closing. Given the update cadence described above, this is a material risk, not a drafting refinement. Von Firn's piece is the deal-layer complement to our earlier analysis of change-in-law MAC clauses after the 20th Russia package. Together the two articles cover both the statutory change and the listing event — the two scenarios your SPA needs separate answers for.

Including cobalt in Swiss responsible business due diligence has been a civil society ask since the 2021 RBI counter-proposal — and the NUFG Vernehmlassung that closes today is the next procedural moment where that argument could be registered. The case runs: the EU CSDDD will reach Swiss exporters contractually regardless — we mapped this in May — so excluding cobalt from Swiss legislation creates a compliance mismatch rather than reducing the burden. If cobalt goes in, the documentation requirements for electronics, battery, and EV-adjacent supply chains increase substantially. Whether the Federal Council's Vernehmlassungsbericht reflects cobalt submissions will be visible when it is published; by the time parliamentary debate begins, the scope will have already narrowed.

FINMA announced in February that its Zurich office moves from the city centre to Oerlikon. Operationally reasonable; worth flagging to whoever coordinates your supervisory contact before the next scheduled visit lands at the old address. The February announcement confirmed the date: November 2026. Update the contact file now.

Hunton Andrews Kurth is the latest US firm to close a China office, accelerating a multi-year contraction of Western law firm presence in Beijing and Shanghai. For Swiss in-house teams with M&A, disputes, or operational matters touching Chinese counterparties: check which panel firms are still resourced on both sides. Many are now operating through best-friend referral networks rather than owned offices, which changes response times, privilege questions, and cost structures. A panel review before you need emergency China coverage is worth scheduling for Q3 — not after the deal is signed.

More foreign bribery cases opened in Switzerland — a headline that needs calibration. The case count does not tell you about close rates, nor about the corporate liability trigger under Art. 102 Abs. 2 StGB, which remains the lever most prosecutors have not yet pulled with confidence. The provision makes Swiss legal entities criminally liable for foreign bribery where they failed to take all reasonable organisational measures to prevent it — and "all reasonable measures" requires documentation that most compliance programs cannot yet produce on demand. A rising prosecution count is exactly the right moment to run that stress test. Our May analysis of the enforcement gap is the starting point; the Art. 322septies nexus piece covers the individual dimension.

The debate over Russian frozen assets in Swiss banks keeps producing coverage. The legal position has not moved: a Sperrung under the Embargogesetz immobilises assets but does not transfer title, and the path from immobilisation to confiscation to transfer requires a constitutional footing that does not yet exist. We covered this in May. What is worth watching now is whether the bilateral Schweiz–EU package negotiations introduce any political pressure to align Swiss asset treatment with the EU's windfall-profits approach — a different legal mechanism pointing in the same direction.

The implementing ordinance for the Investitionsprüfgesetz is where the real lobbying is happening right now, mostly out of sight. Sector definitions written broadly generate mandatory notifications for transactions that deal teams assumed were exempt; written narrowly, the law looks as light as it was marketed. We made the deal-execution case in May: screening risk belongs in the term sheet, not in post-signing discovery. The Bundesrat published the Investitionsprüfverordnung draft for Vernehmlassung on 12 June 2026; the sector definitions are in the document now and are the clauses to read before your next cross-border acquisition mandate.