The partial revision of the AMLO-FINMA closes for comment on 9 June 2026. FINMA describes the revision as a "codification of current supervisory practice" — operationally, that framing matters less than what the four areas of revision actually require. The changes tighten interpretation of existing duties on beneficial-owner transparency, enhanced due-diligence triggers, third-party verification, and Embargo Act / coercive-measures compliance. Interpretive tightening does not go through parliamentary debate and is harder to challenge once finalised. Our 16 May analysis identified the operative clauses; our 27 May piece assessed the practical burden for compliance teams. Drafting a focused two-page comment is achievable before the deadline. Silence is not a neutral position.

Today's two feature articles on this site cover issues that look unrelated and are not. Casimir von Firn's guide to the new beneficial-owner register maps the disclosure architecture — which Swiss legal entities must now declare what about their ownership chain, and when. Dr. iur. Servatius von Tatzenberg's piece explains why Switzerland cannot transfer frozen Russian assets to Ukraine even where the political will exists: the legal distance between "frozen" and "forfeited" requires a specific domestic legal instrument that Swiss law does not currently contain. The two instruments operate in legally independent domains: the Embargo Act / Art. 26 BV framework governs what can be restricted and for how long; the LETA register records who owns what. The mechanism that would convert a restriction into a change of ownership is a different, and currently non-existent, legal instrument — and that gap, not some unified Swiss architecture, is what the summer's legislative discussion will turn on.

WBF updated the Sudan ordinance annex (SR 946.231.18) and SECO updated the Taliban list (SR 946.231.07) on the same date. Routine, but a useful prompt: verify that your screening system pulls these as independent lists rather than as one aggregate "SECO output." As our 23 May piece documented for SR 946.231.18, Swiss and EU list timings diverge by days to weeks — a single EU-mirrored feed is not a reliable proxy for Swiss compliance.

SECO updated the ISIL/Al-Qaida sanctions list in April. As our 26 May article explained, SR 946.231.08 runs on the UN 1267 track — names bind in Switzerland the moment the Security Council adds them, without the Federal Council enacting any individual implementing ordinance. Screening workflows that use jurisdiction flags to trigger a deeper check miss this list almost by design. If your process relies on country-based filters, you are not seeing SR 946.231.08 entries until after they are already legally binding.

WBF amended Annexes 12 and 14 of SR 946.231.143.6, the comprehensive Iran ordinance in force since 12 December 2025. Our 18 May article covers the scope change. The key calibration point for screening teams: the current ordinance's prohibition perimeter is materially wider than the framework it replaced. Any Iran-related transaction review calibrated to the pre-December 2025 text needs to be reset before the next transaction closes — a list amendment and a scope amendment interact in ways that are easy to miss if you update one and not the other.

In C-747/22 (INPS), decided 7 May, the Grand Chamber held that requiring habitual residence to access social assistance constitutes indirect discrimination where it disproportionately affects third-country nationals who are beneficiaries of international protection (subsidiary protection status). The governing framework is Directive 2011/95 (the Recognition Directive), not EU free-movement law. The discrimination finding runs between Italian nationals and internationally protected third-country nationals — the affected legal class is not EU citizens living outside their home member state. For in-house counsel whose companies employ persons with subsidiary protection status in Italy or other EU member states, the operative question is whether any benefit or social assistance eligibility condition uses a habitual-residence filter that disproportionately burdens that class. If it does, INPS has cleared the doctrinal path for a challenge under the Recognition Directive.

C-133/24 (CD Tondela), decided 30 April, found that no-poach agreements among Portuguese football clubs during the Covid-19 pandemic were restrictions by object under Article 101 TFEU. The clubs' crisis-management rationale — legitimate on its face — did not change the nature of the arrangement. Object restrictions require no proof of actual market harm to be unlawful; the ECJ remitted to the national court the question of whether a sporting-integrity or roster-stability rationale could qualify as a legitimate objective, so the by-object classification is settled without all defences being foreclosed. For Swiss companies with EU operations, the operational implication is direct: any written or informal coordination with a competing employer about not soliciting or hiring each other's staff — regardless of stated purpose — is harder to characterise as anything other than an object restriction. Review consortium agreements, agency arrangements, and HR protocols that contain staffing coordination language across competing entities.

Law.com runs the headline "The Verein Is Dead", which is a verdict, not a provocation. The Swiss Verein allowed globalising law firms to unite under one brand without financial integration — liability separation, autonomous partnerships in each jurisdiction, cheap lateral expansion. DLA Piper's restructuring — effective 1 May 2026 — converts the Verein to a global LLP while preserving regional profit pools; the new structure is not a full financial merger. Kirsten Vasquez of Major Lindsey & Africa characterises the move as signalling "a broader market shift," and other firms examining the model's accumulated disadvantages — inconsistent quality assurance across the network, complex conflict management, and client scepticism at the moment of engagement — are now looking at their own structures. For in-house legal teams, the question surfaces at the engagement letter: a firm that has dissolved its Verein is making an implicit representation about financial solidarity and unified professional standards that a Verein-structure firm cannot make. Worth asking explicitly at your next panel review.

Hunton Andrews Kurth and K&L Gates both confirm Beijing office closures this week. The international law firm footprint in mainland China is contracting toward a smaller number of firms with stronger local integration. The compliance risk attached to Chinese counterparties, joint-venture partners, and supply-chain participants has not contracted at the same pace. For Swiss groups with active China exposure, the practical question is whether your outside-counsel panel in Beijing can handle what you may actually need in the next twelve months — and whether addressing that gap now is easier than scrambling when a specific matter arrives.

The Ethos Foundation and 21 co-signatories — institutional investors and civil-society organisations — are calling for cobalt to be included in the scope of the Nachhaltige Unternehmensführungsgesetz (NUFG) during the Federal Council's Vernehmlassung consultation, which runs until 9 July 2026. Parliament has not yet engaged; at this stage the pressure channel is the consultation response, not the legislative chamber. The connection to the EU CSDDD is immediate: as our 18 May piece set out, Swiss companies supplying EU buyers are already contractually subject to CSDDD due-diligence requirements whether or not Swiss domestic law requires the same. The NUFG's scope will determine whether Swiss law aligns with that contractual reality or leaves a structured gap. Cobalt is one of the minerals where CSDDD traceability obligations bite hardest in practice. Whether it enters the NUFG will be an early signal about how seriously Switzerland intends to harmonise with EU supply-chain standards.

FINMA confirmed it will move its Zürich presence from the city centre to Zürich-Oerlikon, citing lower cost per workstation and improved working conditions. The relocation is scheduled for November 2026 per the 6 February 2026 FINMA press release. Practical note: update your supervisory-dialogue calendar templates and any counterparty-records systems before the move — and flag the November 2026 date in any supervisory-dialogue schedules that extend into that period.

The Solicitors Regulation Authority has seen misconduct complaints rise by more than half since 2024, with its investigation caseload tracking that increase. The SRA's proposed 29% funding increase is a downstream effect. For Swiss companies instructing English solicitors — and most do — the takeaway is not alarm but situational awareness: firms under sustained regulatory pressure sometimes deprioritise matter management and client communication in ways that have direct consequences for the companies they represent. It is a reasonable question at your next panel review: how is your UK firm handling the current SRA environment?