Das Tageslog

Mittwoch, 15. Juli 2026

Dr. iur. Servatius von Tatzenberg

Six sanctions annexes have moved since March, and this week's FINMA batch caught up on the whole run at once — the loudest one, Russia, was still the least interesting.

SECO's Sudan annex gets a rewrite — still trailing Brussels

FINMA News

The WBF touched the Sudan sanctions ordinance again — the same Anhang 2 of SR 946.231.18 whose February revision we flagged for landing twenty days after Brussels. The pattern holds: Bern updates on its own clock, and a screening tool keyed only to the EU consolidated list will miss this gap the same way it did last time.

Al-Kaida/ISIL list moves again — still on the UN track, not the EU one

FINMA News

SECO updated the ISIL/Al-Kaida list under SR 946.231.08 — the ordinance we described as running on the UN 1267 track since March 2025. Names bind in Bern the moment New York's Sanctions Committee lists them; there is no EU intermediary step to watch for, which means an EU-list-only screening feed will never catch this one at all.

Iran ordinance gets another annex update — the cadence since December holds

FINMA News

Anhänge 12 and 14 of the Iran measures ordinance were amended again — the latest in a steady run of annex updates since the 12 December 2025 total revision we wrote up as replacing the JCPOA-era framework. This is at least the fourth annex touch since then, after updates in late December, February and late February/early March. The new architecture is clearly getting maintained; whether your screening feed is keeping pace with it is the harder question.

Anhang 8 of the Russia ordinance changes — the list everyone already screens

FINMA News

The WBF amended Anhang 8 of SR 946.231.176.72. Unlike Sudan or Iran, this one gets watched by every compliance vendor in the market — but "watched" and "current" are not the same claim, and each amendment is a fresh occasion to confirm the vendor actually ingested the update rather than just the entries that made headlines.

The Hamas/PIJ sanctions ordinance nobody screens for got updated too

FINMA News

SR 946.231.09 — measures against persons and organisations supporting Hamas and Palestinian Islamic Jihad, in force since 10 April 2024 — had its annex amended again. It rarely makes anyone's shortlist of "the regimes we screen against," which sits alongside Russia and Iran on every deck. A compliance program built around the loud regimes has a blind spot shaped exactly like this one.

Prognose: This ordinance surfaces in an enforcement file before it surfaces in a training deck.

Taliban list updated — the sixth sanctions annex change since March

FINMA News

SECO amended the list under SR 946.231.07. Nothing dramatic on its own, but tally the run since March: Sudan, ISIL, Iran, Russia, Hamas/PIJ, now Taliban. "Sanctions screening" is not one list to reconcile against — it is at least six independently maintained ones, each on its own update cadence, and a single missed feed breaks the whole exercise quietly.

FINMA formally opens the AMLO-FINMA consultation — deadline still 9 June

FINMA News (en)

The consultation we covered from the draft side — "no new obligations," FINMA said, and three clauses that shift the burden of proof anyway — is now formally live as of 12 May. The deadline has not moved. If your compliance team hasn't drafted a response yet, there is less runway left than the "no new obligations" framing suggests.

Prognose: Expect the response trickle to arrive in the final week before 9 June — don't be the trickle.

Swiss NGOs push to add cobalt to the responsible-business rules

SWI swissinfo.ch (en)

Campaigners want cobalt added to the mineral scope of Swiss responsible-business legislation. Worth reading next to the point we made about the CSDDD already binding Swiss exporters contractually, ahead of any NUFG vote: the domestic fight over which minerals count in Bern is somewhat beside the point for exporters whose EU customers already require CSDDD-equivalent diligence covering cobalt regardless of what gets enacted here.

Why pro-business Switzerland is warming to investment screening

SWI swissinfo.ch (en)

A useful primer on the politics behind a law we called "light touch" in name only. The parliamentary debate produced a real gatekeeping mechanism, and it belongs in the term sheet, not the closing memo.

Proton's surveillance-law win, years on, is still the citation everyone reaches for

SWI swissinfo.ch (en)

Nothing new here beyond a recap, but a reminder that the BVGer line we wrote up as holding for five years is still the reference point every derived-communication-service provider cites first. No sign of Bern trying to legislate around it yet.

Later today: what Commission v Malta does to your onboarding file once a residency claim starts reading like a red flag — for now, go check which sanctions feeds your vendor actually pulled this week.