The partial revision of the FINMA Anti-Money Laundering Ordinance had a consultation deadline of 9 June — yesterday. If your compliance or legal team planned to respond and didn't, that window is permanently closed. What comes next: FINMA consolidates the submissions, usually within 60–90 days, and issues the final ordinance. Industry commentary has framed the revision as "keine neuen Pflichten" — accurate in the narrow sense: no categories of obliged party are added. But the three clauses on beneficial owner transparency shift what counts as adequate documentation in borderline situations. That's a practical change even if it isn't a structural one. Worth asking your AML officer whether your firm submitted a position, and if not, whether you want to be on record with FINMA through an industry association before the final text drops.

The WBF amended Annex 2 of the Sudan Ordinance (SR 946.231.18) on 4 June, effective at 23:00. Routine screening hygiene — but as we have noted before, Switzerland's Sudan list has historically run twenty days behind EU listings. Check whether your screening vendor pushed this update automatically. If your system requires a manual trigger, this is that trigger.

SECO updated the Taliban ordinance list in SESAM on 29 April, following the UN sanctions committee decision of 28 April. These FINMA sanction bulletins are easy to bury in the feed — but each one is a binding update on the day of entry, running on the UNO-1267 channel. The practical question is not whether you have the list — it's whether your vendor's update lag means you screened a transaction on the old version after the new one was in force.

Today's piece from Dr. iur. Servatius von Tatzenberg covers the Art. 5 prohibited practices that have been enforceable since 2 February 2025 — not the high-risk Annex III obligations everybody is preparing for, but the flat prohibitions that were already in force more than sixteen months ago. The specific exposure for Swiss companies: emotion recognition in the workplace, untargeted facial scraping from the internet, and profiling-based risk scoring that generates inferences about individuals from proxies. None of these required a new vendor contract; all of them can appear inside systems acquired for entirely different purposes. The article maps which everyday corporate AI deployments land inside the prohibition rather than the high-risk tier. Published today at /de/eu-ai-act-art-5-verbotene-praktiken/ — send it to whoever owns your AI inventory.

Swissinfo's piece on AI deployment at EU border checkpoints runs on the same day as our Art. 5 analysis, and the two are worth reading together. Border biometric systems sit squarely in Annex III of the AI Act — the high-risk tier — and the Annex III high-risk compliance deadline was extended in May to 2 December 2027 under the Digital Omnibus package, a sixteen-month delay from the original August 2026 date. Swiss vendors supplying or operating these systems have gained runway, but the architecture work is not discretionary — compliance structures for high-risk AI take time to build and audit. The Swissinfo piece is useful background for those coming to the topic fresh; the operative classification is in today's Von Tatzenberg briefing.

The Swissinfo CO2 ballot explainer keeps circulating. The important clarification for in-house counsel: the ballot outcome on the CO2 law has no effect on the climate reporting obligation already operative under Art. 964b OR. The Klimaberichterstattung requirement runs on its own statutory track. If your sustainability team is using "the CO2 law was rejected" to defer disclosure work, they are conflating two separate instruments. The Art. 964b obligation is live regardless of what happens at any referendum.

Another US firm exits China, joining a list that has grown steadily for two years. The practical effect for Swiss in-house teams: the pool of international firms able to run integrated cross-border China work from a single desk is contracting. What fills the gap is Hong Kong rates plus local firm coordination — more expensive, slower on document review, and with a harder privilege question on communications that cross the boundary. Not a crisis today, but worth a line in the next outside counsel spend review.

The Swissinfo investment screening explainer resurfaces — a useful primer for those new to the topic, but the framing of the Investitionsprüfgesetz as "light touch" has aged poorly. The parliamentary process produced a more substantive regime than the name suggests. Screening risk belongs in the term sheet, not the closing checklist, and for deal teams in critical infrastructure sectors, the trigger sectors — electricity, healthcare, telecom, railways, airports, logistics — may land closer to home than assumed going into a mandate.

The Swissinfo Russian assets piece keeps recirculating, which usually means somebody senior asked a question and someone reached for a news search. The legal position is unchanged: a freeze under the Embargogesetz immobilises assets and does not transfer title. The Art. 26 BV constraint has not been resolved by any legislative move. The structural problem — frozen is not confiscated — remains, and anyone expecting Switzerland to shift toward outright confiscation should be reading the Federal Council dispatch and committee reports, not news aggregators.

Swissinfo notes more Swiss foreign bribery prosecutions, but gaps remain. The correct interpretation of the gap: Art. 102 Abs. 2 StGB makes corporate liability real, but prosecution requires evidence of a compliance failure, and "we have a policy" does not satisfy the "it was actually implemented" test. Companies in construction, energy, and any sector with agents in emerging markets who have a gifts policy but no audit trail of how it is applied are the exposure. The policy is the easy part.

The perennial Rolex question. The correct answer: Art. 322septies StGB has no CHF threshold. Whether the gift constitutes foreign bribery turns on the nexus to an official act, not the price tag. The tatbezug, not the value, is what prosecutors look at. If your gifts and entertainment policy still lists a monetary limit as the primary compliance control, it is built on the wrong legal model. The CHF amount is relevant to internal escalation triggers, not to the criminal law analysis.

FINMA announced its Zurich office moves to Oerlikon to cut cost per workstation. Administrative — but a regulator managing its own budget tightly tends to concentrate enforcement bandwidth on areas where it has jurisdiction confidence and clear statutory hooks, and less on exploratory enquiries at the edges of its mandate. That's not reassuring if you are sitting in the crypto or AI-in-finance space, where the statutory hooks are new and FINMA has been building out expertise. Worth keeping in mind when estimating how proactive the authority will be on emerging issues through 2027.