Anhang 8 of the Russia ordinance moved this week, and in the same fortnight so did the Taliban list, Anhang 2 of the Sudan ordinance — the same instrument we flagged in May for lagging Brussels by twenty days — and the general sanctions annex. None of these are "new sanctions" in the sense a general counsel briefing would flag. All four require a re-run against your existing counterparty list, because the annex, not the ordinance headline, is where names get added and dropped.

SR 946.231.08 — the instrument riding the UN 1267 track we wrote about in May — was amended in April and again this month. Two revisions in three months is a pace change, not noise; if your screening cadence assumes UN-track lists move slower than EU/OFAC ones, this is the counterexample to bring to your next compliance committee.

The post-JCPOA Iran ordinance we covered back in May keeps growing at the annex level rather than the headline level — exactly the pattern that makes it easy to certify compliance against last quarter's list and be technically wrong today.

Commission v Hungary asks the question the Article 2/4(2) TEU relationship has been avoiding: when does a member state's claim to constitutional identity stop being a shield and start being a breach of the Union's core values? The blog's read is that the Court left the balancing test unfinished on purpose — a deliberate non-answer that keeps every future identity defense on a shorter leash than before.

This matters here for a reason that has nothing to do with Hungary: under Bilaterale III's dynamic rule-adoption clause, EuGH doctrine on how far Union values reach into domestic law doesn't stay in Brussels. It becomes interpretive gravity for the bilateral agreements the moment it's decided.

No new development, just a reminder the ruling is still doing work: we laid out the proportionality reasoning and what it means for derived-communication-service providers here. If your surveillance-cooperation policy hasn't been updated since A-5373/2020, it's overdue.

Today's roundup of Russian assets frozen in Swiss banks reads a lot better next to the Magnitsky retrospective right beside it on the same section front: freezing under the Embargo Act has never required Switzerland to actually investigate the money, and it still doesn't. That's the exact gap we mapped in "Gesperrt, nicht eingezogen" — a freeze immobilizes title, it does not transfer it. Nothing about today's numbers changes that.

One piece asks whether Switzerland is closing its foreign-bribery enforcement gap; the other asks whether a Rolex to a foreign official even counts as bribery. Read together they answer each other: it's not the gift value that closes the case, it's the connection to an official act — which is exactly the line we drew in Art. 322septies, Tatbezug statt Geschenkschwelle. The enforcement gap isn't a missing threshold. It's a missing compliance program under Art. 102 para. 2 StGB — the corporate liability angle these two pieces both skip.

Whether cobalt gets named in Swiss due-diligence legislation is a lobbying question, not a legal one at this point — the substance is already arriving through the front door. Read next to today's piece on the EU supply-chain crackdown, the picture is: the NUFG consultation is still deciding what a Swiss law should say, while the CSDDD already binds Swiss exporters through their contracts — the exact sequencing problem we mapped in "CSDDD vor NUFG".

Same day, same border: cobalt sourcing on the way in, screened investment on the way in from the other direction. Both are Switzerland deciding, piecemeal, that "open economy" no longer means "no questions asked" at the border. We covered the term-sheet consequences here — the "light touch" framing hasn't survived contact with the parliamentary committee.

The comparison to Britain is doing a lot of work in this headline that the text doesn't quite earn, but the underlying discomfort is real: Bilaterale III trades market access for continuous rule-taking. We already argued that duty starts now, not at ratification — and per the Hungary item above, "rule-taking" now includes whatever the EuGH decides Article 2 TEU means this year.

FINMA's liquidation order survived the Bundesverwaltungsgericht appeal months ago; what it didn't settle is what Art. 37a BankG actually guarantees a depositor's operating account once liquidation starts. Today's full piece on the site takes that question on directly — worth the read if your treasury team has ever assumed "privileged deposit" means "business as usual."

The business is already deployed; the Annex III high-risk obligations for border biometrics don't bind until 2027, per the provisional deal we covered in May. Today's separate piece on Art. 25 KI-VO looks at the other side of that same gap — the procurement contract that quietly converts a Swiss operator into an AI provider under the Regulation, deadline or no deadline.