Russia (Anhang 8), Sudan (Anhang 2), Iran (Anhänge 12 und 14), and a general update to SR 946.231.09 all landed as separate FINMA notices this cycle — each one a one-line echo of a WBF or SECO ordinance change, not new law. The Taliban list update gets its own full treatment today (out later), so no repeat here. What's actually worth noting: FINMA's notice function is purely relay — the binding text sits in the annex itself, dated separately from the EU listing it mirrors. If your screening vendor is keyed to FINMA's publication date rather than the WBF ordinance date, you have a gap, and it's the same gap we flagged in the UNO-Schiene piece.

We covered this twice already ("keine neuen Pflichten" and the burden-shift read) — nothing new to add until FINMA publishes the results. File this as a tickler, not a task.

Already dissected in TBTF, third anlauf and the four missing instruments piece. FINMA's own statement adds nothing beyond "we welcome it" — the gaps we identified stand.

Our earlier piece already made the point: the press text is not the supervisory mandate. If you skipped that one, this is your reminder.

Two of our pieces already put this where it belongs — Art. 12 BankV, not Art. 9 GwG, and why fraud KPIs belong at board level given Art. 146 StGB's predicate-offence status. No update to either read.

The Swiss appeal survived FINMA's own process and the Bundesverwaltungsgericht — Washington is a different fight entirely, and FinCEN's "primary money laundering concern" designation doesn't move regardless of the domestic outcome. Anyone still treating this as one story is going to be surprised twice.

This is the same BVGer line (A-5373/2020) we walked through in "VÜPF nach Proton" — the swissinfo piece is the plain-language version of a ruling that will sit in every telecom and messaging-app general counsel's file for a while. The five-year holding pattern is over; the burden question isn't.

Short version, already in our Investitionsprüfgesetz piece: "light touch" was the marketing, a genuine screening gate is what came out of committee. Put it in the term sheet.

Covered in depth in CSDDD vor NUFG — the NUFG vernehmlassung is still pending, the CSDDD contractual pass-through from EU customers isn't waiting for it.

The "Brexit ghosts" framing is journalistic flourish; the substance is in what dynamic rechtsübernahme already requires today and in the state-aid control piece — your legal department doesn't need to wait for ratification to start tracking EuGH case law on the Binnenmarktabkommen sectors.

The provisional deferral of Annex III high-risk duties in border biometrics runs to 2027 — we covered the mechanics in May — but the money is already moving, per this piece. A deferred obligation is not a deferred market; contracts signed now will still need to be Annex-III-compliant when the clock runs out, and nobody drafts for a 2027 requirement in a 2026 procurement unless someone makes them.

Consistent with our Art. 102 Abs. 2 StGB piece: the statute has teeth, the enforcement gap sits entirely in whether a company can show an organized compliance program. Nothing here changes that math.