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FINMA's partial revision of the AMLO-FINMA, in consultation until 9 June 2026, rewrites three clauses on ownership transparency, sanctions controls and correspondent banking. The drafting shifts the documentary burden of proof for KYC and monitoring gaps back onto the Institute.
FINMA's early-February 2026 licence revocation against MBaer Merchant Bank AG carried suspensive effect on appeal. FinCEN's Section 311 notice did not — and once a Swiss merchant bank loses its U.S. dollar correspondent line, the rest is paperwork.
The Bundesrat's Botschaft on the BankG-Revision arrived on 22 April 2026 carrying three schedules: USD 20 billion of additional CET1, a Senior Manager Regime, and a FINMA Bussenkompetenz, together re-papering the Verwaltungsrat's relationship to its supervisor under Swiss federal law. This is the clause walk: what each lever pulls, where the litigation will live, and the question Parliament cannot answer before 2033.
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