Today's piece by Dr. iur. Servatius von Tatzenberg — Art. 47 BankG Meets Art. 271 StGB — puts a direct answer on a question compliance teams rehearse but rarely resolve: when a foreign authority requests information directly, Art. 47 BankG prohibits disclosure, and Art. 271 StGB may make acting as a foreign state's instrument an offence in its own right. The article's finding is that the safe harbour depends entirely on routing — whether FINMA, the MLCA, or a bilateral MLA procedure was engaged before any disclosure decision was taken, not on the content of the disclosure itself. If your escalation matrix does not explicitly name the routing authority as the first decision point, the matrix is incomplete. The BankG revision currently before Parliament adds capital and resolution tools but leaves this information-sharing architecture to existing treaty and MLA practice.

The second piece today — Will the State e-ID Retire Video Identification? — asks the question the BGEID drafters declined to answer in the legislative text: if the Confederation now issues a high-assurance electronic identity, what happens to the parallel financial-sector video-ID infrastructure built under Rundschreiben 2016/7? A state e-ID establishes identity; it does not automatically substitute for AML ongoing monitoring obligations or the enhanced due diligence triggers in Art. 13 AML Act. The article maps where the gap sits and what the GwV-FINMA partial revision — in consultation until 9 June — leaves unaddressed. The two texts will need to mesh; right now they do not address the interface at all.

The partial revision of the GwV-FINMA has been in consultation since 12 May and closes 9 June 2026. FINMA's framing — "no new obligations" — holds for the formal structure but not for the examination practice that follows. As our coverage last week showed, three clauses on beneficial ownership transparency shift the practical burden of proof in ways that will appear in audit letters long before they reach enforcement decisions. Twelve days is enough time for a first read. If your industry association has not coordinated a response by now, it probably will not.

FINMA posted sanction list updates for Sudan (SR 946.231.18) and Taliban (SR 946.231.07) on May 1, and ISIL/Al-Qaeda (SR 946.231.08) on April 1. None is a structural revision. The ISIL update is the one to process first: as we noted in May, the UN 1267-track list binds in Switzerland without the usual country-level screening step, and the gap between UN publication and Swiss gazette entry remains a configuration problem for automated tools. If your system relies on a country flag to catch 1267-track names, this update will not trigger it.

In C-747/22 INPS, decided 7 May, the Grand Chamber held that a ten-year national residency condition applied to the withdrawal of social assistance from a beneficiary of subsidiary protection constitutes indirect discrimination prohibited under Art. 29 of the EU Qualification Directive (2011/95/EU). The protected class is third-country nationals holding subsidiary protection status — not EU workers exercising free movement rights. The comparator is Italian nationals, who faced no equivalent residency bar. For in-house counsel at EU-operating companies employing persons with international protection status, the operative obligation tracks Art. 29: equal treatment in social security and social protection. Any benefit-access condition that requires uninterrupted national residency must be tested against this standard when applied to employees holding international protection status. The proportionality test applied is the same the Court uses for formally neutral measures that systematically disadvantage a protected population — cost savings alone do not justify it. Swiss counsel whose EU subsidiaries employ beneficiaries of subsidiary protection should review whether benefit-conditioning clauses in local employment contracts survive this scrutiny; the case has no direct equivalent in Swiss domestic law but binds through the law of any EU entity in the group.

In C-133/24 CD Tondela, the Court addressed no-poach agreements between Portuguese football clubs during Covid-19 and held that agreements between competitors not to recruit each other's employees are to be classified as restrictions by object under Art. 101 TFEU — unless a specific examination of the agreement's content, objective aims from a competition standpoint, and economic and legal context indicates otherwise. No market effect needs to be proved to engage the prohibition, but the by-object classification is presumptive and rebuttable, not categorical. The Court explicitly applied the Wouters/Meca-Medina framework, recognising that ensuring the regularity of sporting competitions constitutes a legitimate objective that may justify arrangements otherwise caught by Art. 101 — that avenue remains available. The CJEU referred the final contextual classification back to the Portuguese national court for an in-depth examination. The Court treated labour as a competitive input like any other and applied standard cartel analysis. Swiss in-house counsel at companies with informal non-solicitation understandings with competitors — the kind that lives in side letters, founders' emails, or unwritten industry convention — should treat this as the trigger for a review. DG COMP's labour-market enforcement agenda has been moving toward this position for two years; the Court has now provided the doctrinal anchor that national authorities, including WEKO, can use directly.

Baker McKenzie is rolling out Legora firm-wide across all six global practice groups simultaneously. The point of interest for in-house counsel is not the technology selection but the governance signal: if the firm advising you on a cross-border matter is running AI-assisted research and drafting at scale, the question of who reviewed the AI output — and whether that review is visible in the advice — is a legitimate client question. Most large firms have AI governance policies. Very few volunteer the details unprompted. This is a reasonable moment to ask.

FINMA's Zurich office moves from the city centre to Zurich-Oerlikon — lower operating costs, better working conditions per workstation, same supervisory mandate. The institutional observation worth logging: Oerlikon is becoming the de facto campus for Swiss financial and technology regulatory bodies, which concentrates informal access to multiple regulators in a single district. Examination teams based in Oerlikon will have different coffee-meeting geography than teams based near Bahnhofstrasse, and informal briefing culture shifts with the commute.

The parliamentary environment committee has recommended adding cobalt to the minerals covered by Switzerland's responsible business due diligence framework. The practical effect: battery-sector supply chains and EV component manufacturers would come explicitly into domestic scope before the NUFG consultation has even concluded. For Swiss exporters already contractually committed to EU-level CSDDD standards through their German and French customer contracts, this is gap-narrowing — the domestic legislative floor is moving toward a standard they are already required to meet. For those who have not yet mapped their cobalt sourcing, the voluntary compliance window is compressing.

DLA Piper is dissolving its Swiss Verein — the legal fiction that allowed global firms to combine national practices under a shared brand without full financial integration. The Verein gave member practices ring-fenced liability and kept profit-sharing at the national level; its unwinding signals a shift toward shared economic risk across jurisdictions. For in-house counsel, the practical question is conflict-check scope: a DLA Piper operating under a single global LLP — with separate profit pools remaining in the initial phase and full financial integration as the stated future goal — has fewer structural barriers to conflicts across practice areas than a loosely federated Verein did. If you have active matters running through multiple DLA offices, it is worth a direct conversation with your relationship partner about how the restructuring affects your existing conflict waiver arrangements.

Swissinfo surveys Switzerland's foreign bribery enforcement record: more cases are being opened, but the corporate liability track under Art. 102 para. 2 StGB remains underused relative to the size of the Swiss export economy — a finding the OECD Working Group on Bribery has returned in its Switzerland country monitoring. The structural explanation has not changed: compliance programs designed around Art. 322septies personal liability routinely miss the Art. 102 organisational test, which asks whether the company took all reasonable precautions to prevent the offence — a more demanding standard than the gift-policy checklist. If your program was last reviewed before the Trafigura decision, it is due for a stress-test against the Tatbezug standard.