Casimir von Firn's piece today is the one to forward to whoever is signing AI procurement contracts this quarter. The Hilfsperson doctrine is not new law — it is Art. 101 OR applied to a new fact pattern. The interesting question is not whether the employer is liable for the agent's acts (it is) but whether the contract with the vendor is structured so that liability can flow upstream when it needs to. If you do not own the system prompt and cannot produce the audit log, you own the loss.

WBF updated Annex 2 of the Sudan ordinance (SR 946.231.18): the change was effective June 4, 2026 at 23:00; the FINMA notice was published June 5. If your screening runs weekly or fortnightly and ran before 23:00 on June 4, it missed the update. Pull the diff. We noted the Swiss-to-Brussels lag pattern for this ordinance in May — the June 4 operative date is consistent with it.

The partial revision of the FINMA Anti-Money Laundering Ordinance closed for comment on 9 June. If you submitted a response, file it somewhere you can find it in September. If you did not, the three ownership-transparency clauses we mapped in May are where the final text is most likely to surprise compliance teams that read the consultation draft but did not track what changed between draft and comment.

FINMA revoked MBaer's banking licence approximately three weeks before February 27; the bank appealed and the Federal Administrative Court granted suspensive effect, prohibiting FINMA from enforcing the liquidation order. The FinCEN primary-money-laundering-concern designation landed on February 26 — one day before MBaer voluntarily withdrew its appeal, making the liquidation order effective. As we wrote in May, the FinCEN designation was the external trigger for the appeal withdrawal, but the licensing outcome was Swiss Banking Act law. The compliance lesson for every bank with US correspondent exposure: a FinCEN designation is not just the client's American problem, and the Swiss timeline is faster than most risk committees have modelled.

FINMA's April 22 statement on the BankG dispatch is more useful as a signalling document than as a summary. The four instruments FINMA considers missing — covered in detail in our May analysis — are the ones that would give the regulator senior-manager-regime-style accountability levers. The parliamentary committee hearings are where those four items will either survive or be traded away; FINMA's public position sets the floor for its lobbying in committee.

FINMA's April 9 guidance (Aufsichtsmitteilung 02/2026) addressed the categorisation question banks had been asking informally for two years: digital fraud spans operational risk management and AML prevention, without a clean either/or division. The compliance question the guidance actually poses is which function owns the risk management framework — not whether AML obligations are disapplied. We ran the full analysis in May. If your fraud prevention sits entirely inside the AML function, the guidance is a reorganisation signal, not a minor structural question.

January's FINMA guidance on crypto custody (Aufsichtsmitteilung 01/2026) — the full guidance document, rather than the press release — moved the segregation analysis from the general ledger to the wallet level. Six months on, institutions that have not yet documented their wallet-level custody arrangements are the ones that will be surprised in the next examination cycle. The full picture is in our May piece. Put this on the next board risk committee agenda if it has not already appeared.

SECO revised the Taliban ordinance (SR 946.231.07): the UN sanctions committee acted on April 28, the change became effective in Switzerland on April 29, and the FINMA notice was published May 1 — for screening purposes, April 29 is the controlling date. The Taliban list operates on the UNO-1988 track (UN Security Council resolution 1988, 2011), which is a separate committee and designation procedure from the 1267/1989/2253 track governing ISIL and Al-Qaida (SR 946.231.08). As we wrote in May, designations on both tracks bind in every transaction regardless of geography — country-based screening filters do not catch them. If your screening tool's default logic is country-first, both lists require a separate pass.

Foreign law firms are pulling back from Hong Kong — headcount reductions, consolidations, some full closures. The same firms expanding into the Philippines and Saudi Arabia are the ones contracting in Hong Kong — the capital is moving, not disappearing. For Swiss in-house teams with Asia mandates, this means a narrower panel, longer response times for Hong Kong-seated arbitrations, and price pressure from the firms still standing. If your external counsel panel has not been reviewed for Asia coverage in eighteen months, the market has moved under it.

Swissinfo reports on AI deployment at EU border control — biometric screening, risk scoring, watchlist matching. The regulatory frame is Art. 5 KI-VO (prohibited practices) and Annex III (high-risk systems requiring conformity assessment before deployment). We noted in May that the Annex III deadline was pushed to 2027 — which is almost certainly why procurement is accelerating now. Today's piece on AI agent liability under Art. 101 OR is the private-law companion to the public-procurement story: the liability architecture question is the same whether the contracting party is a border authority or a bank.

The Greenland episode is a reminder that international law operates on political will as much as formal obligation — a working assumption that contract and sanctions lawyers already carry but compliance programmes sometimes underweight. The bilateral Switzerland–EU architecture is built on the same premise: the institutional mechanisms that make it function are only as durable as both parties' interest in maintaining them. Not a crisis this week, but a useful frame for anyone advising on long-duration cross-border arrangements.

FINMA announced in February that its Zurich city-centre office will relocate to Oerlikon in November 2026. If you have supervisory meetings in Zurich scheduled for Q4 2026 or later, verify the location before you book travel. The Oerlikon campus is a different commute from Bahnhof Zürich than the current address.