The Daily Log

Sunday, 2 August 2026

Dr. iur. Servatius von Tatzenberg

Tuesday's queue was six sanctions annexes, one regulator quietly outpacing another by three weeks, and two unrelated stories that turn out to be the same problem wearing different letterhead.

Six Sanctions Annexes Updated in a Week — None of Them Touch the Permit Your Screening Software Can't Issue

FINMA News (de)

Six separate sanctions-annex updates landed in the FINMA feed this week alone — Russia, the Taliban, Sudan, ISIL/Al-Qaida twice (April, July), and Iran. None of it will surprise your screening vendor — the name-matching list updates itself overnight. What it won't do is issue the export permit. We wrote about exactly this gap yesterday: Art. 3 Abs. 1 GKV ties the authorization to the goods and the declared end-use, not to whether the counterparty cleared the list. A clean screening report and a missing export permit are two different files, and customs only checks one of them.

FinCEN Calls MBaer a Primary Money-Laundering Concern — Three Weeks After FINMA Had Already Closed the File

FINMA News

The US Treasury's Financial Crimes Enforcement Network designated MBaer Merchant Bank AG a primary money-laundering concern under its Section 311 authority — three weeks after FINMA had already concluded its own enforcement proceedings and put the bank into liquidation. That sequencing isn't coordination, it's two supervisors on separate clocks. If your committee sits anywhere near correspondent banking, the lesson isn't about MBaer specifically — it's that a closed FINMA file doesn't close your US exposure, and the gap between the two closings is exactly where a correspondent bank's own review will land.

Prediction: Watch for a Swiss-US supervisory statement on AML coordination before this cycles through the press again — or pointed silence, which would tell you just as much.

FINMA Opens Consultation on a Partial Revision of Its Anti-Money-Laundering Ordinance

FINMA News

Open since 12 May, and it deserves more attention than a one-line item usually gets — ordinance-level AML changes tend to arrive fully formed by the time anyone outside the drafting group notices. If your compliance function hasn't logged a submission date internally, this is the reminder.

FINMA Welcomes the Banking Act Revision Dispatch — Which Tells You Where the Fight Moves Next

FINMA News

Regulators rarely praise a bill's substance unless they helped write the part they're praising. The too-big-to-fail dispatch now heads to parliament, and that's where the capital requirements get negotiated — where the banks with the most at stake will spend the autumn session's lobbying budget.

Prediction: Expect the capital-surcharge provisions, not the resolution-planning sections FINMA is emphasizing, to be the fought-over paragraph once this reaches committee.

FINMA's 2026 Supervisory Priorities: Same Themes, Confirmed Out Loud

FINMA News

Nothing in the annual media conference readout should surprise anyone who's read this year's guidance notices — digital fraud, AML data quality, liquidity, all repeated. The value isn't novelty; it's confirmation of which guidance documents FINMA considers load-bearing enough to say twice.

FINMA's Bank Survey Finds a "Need for Action" on Digital Fraud — Read: Expect a Circular

FINMA News

FINMA surveyed banks on digital fraud risk management and found gaps significant enough to publish as guidance rather than file quietly. Read the polite phrasing for what it is: a warning shot.

Prediction: Guidance that opens with survey results asking for "action" tends to graduate into a circular within a year — budget for it before the consultation draft appears, not after.

NGOs Push to Add Cobalt to Switzerland's Responsible Business Legislation

Swissinfo

The campaign to fold cobalt into due-diligence duties is the gap we mapped two weeks ago: Swiss mineral due diligence under Art. 964j–l OR only ever covered tin, tantalum, tungsten, gold, and child labour — cobalt falls out entirely, which is exactly why it shows up in Annex X of the EU Battery Regulation instead, and why your EU counterparty writes it into the supply contract rather than waiting for Bern. If this campaign goes anywhere, it just makes statutory what your contracts already do.

Corporate Cash to Swiss Universities Draws Scrutiny Over Sponsored Chairs

Swissinfo

We covered the mechanics two weeks ago: sponsorship money to a Swiss chair mostly sits outside the gift-and-advantage directives that would flag it, but it doesn't sit outside Art. 322quinquies StGB if the funding is timed to a decision the company needs. The reporting doesn't allege that here — but it's the pattern our piece walks through, and worth forwarding to whoever signs off on sponsorship budgets.

Switzerland Prosecutes More Bribery Cases, Still Has Gaps — And the Compliance-Training Industry Has Opinions

Swissinfo

Two items worth reading together: Switzerland's assessment that it's prosecuting more foreign bribery cases but still has structural enforcement gaps, and an ACC piece on what makes anti-bribery training effective rather than a checkbox. The connection is uncomfortable: most in-house training decks are built to satisfy the audit, not the enforcement gap the first article describes. If your training deck hasn't changed in two years, it's probably not the gap that's closing.

Proton Wins Its Appeal Over Swiss Surveillance Obligations

Swissinfo

A Swiss court sided with Proton against surveillance obligations the company argued exceeded what Swiss law actually authorizes for a provider of its kind. Short item, long shadow: this is the ruling that gets cited the next time a tech company's counsel pushes back on a Swiss authority asking for data "because everyone else complies."

Prediction: If this holding stands, expect other Swiss-domiciled communications providers to test the same argument against the Federal Intelligence Service's data-request powers.

Why Pro-Business Switzerland Is Reconsidering Foreign Investment Screening — While Another Group Tries to Cut Red Tape

Swissinfo

Here's the connection nobody in either camp seems to be drawing out loud: the same federal apparatus weighing a foreign-investment screening regime also stood up the Mächler working group on 1 July to cut regulatory costs by the end of 2027. An investment-screening statute is, by definition, new regulatory cost — for exactly the kind of foreign capital the finance sector spends its lobbying budget attracting. Somebody in the Bundeshaus will have to decide which mandate wins, and it won't be settled by press release.

Prediction: Watch for the Mächler working group's 2027 timeline to collide publicly with any new FDI-screening statute — one mandate is supposed to shrink the rulebook, the other adds to it.

The annex was longer than the announcement again, as usual — that's where I read first.