The Daily Log

Friday, 19 June 2026

Dr. iur. Servatius von Tatzenberg

Three articles on the VAG reform, two sanctions updates in four days, and the China office closures are speeding up — not a quiet Thursday.

VAG Reform at Two: The Insurer Still Holds the Distribution Risk

FINMA (de)

We publish three pieces on the revised Versicherungsaufsichtsgesetz today, two years into the reform's enforcement life. The through-line across all three: the VAG shifted distribution accountability from the broker to the insurer, and that shift has not been fully operationalised by most affected companies. Dr. von Tatzenberg's pieces cover the supervisory architecture and the pre-contractual information obligations; von Firn's piece maps the specific Vermittlervertrag clauses that now carry FINMA enforcement exposure. If you have not sent your distribution agreements to your insurance regulatory counsel since January 2024, this is the prompt. The reform is not new — the supervision is.

Russia Sanctions Annex 8 Updated — Three Swiss List Changes in Eleven Days

FINMA News (de)

The WBF amended Anhang 8 of the Russia ordinance (SR 946.231.176.72) on June 16. That follows the Sudan Anhang 2 update (SR 946.231.18, June 5) and an SR 946.231.09 amendment on June 17. Three list changes in eleven days is unusual cadence. For compliance teams: run your screens, log the amendments, and check whether your MAC clause framework — mapped here against the 20th package — catches ordinance-level annex changes, not just named package adoptions. The twenty-day EU-to-Swiss gap we documented for SR 946.231.18 in May has not closed; factor that lag into your screening cycles.

Prediction: A fourth WBF list amendment before end of June is likely — the cadence suggests a coordinated sweep across multiple ordinances, not responses to individual EU designations.

FINMA Moves to Oerlikon — Lower Costs, Same Supervision

FINMA News (de)

FINMA moves its Zurich office from the city centre to Oerlikon, citing lower operating costs per workstation. Worth a calendar update and worth reading as a signal: a regulator managing its own budget while simultaneously running two major consultations (GwV-FINMA, BankG revision) and onboarding a new Banks division chief is a regulator making choices about where to spend capacity. Update the address. The examination teams will be in Oerlikon.

Hong Kong's Foreign Law Firms Keep Shrinking — and the Work Is Not Coming Back

Law.com International

The Law.com tracker on foreign firm headcount in Hong Kong shows a market that is not stabilising — it is repricing. The work that built the Hong Kong offices of US and UK firms (IPOs, M&A, regulatory arbitrage) has either migrated, commoditised, or dried up. What remains is arbitration-seated work and Mainland compliance advice that travels from Beijing or Shanghai. For Swiss GCs with Asia-Pacific panels, the practical question is whether the Hong Kong lawyer you are retaining is actually in Hong Kong, or whether they are being staffed from a regional hub and billing as if they were local. Worth asking the relationship partner directly before the next matter opens.

Prediction: Magic Circle consolidation into Shenzhen and Singapore — not Hong Kong — will show up in annual headcount disclosures by Q1 2027.

Hunton Andrews Kurth Closes China Office — The Retreat Has a Pattern

Law.com International

Hunton Andrews Kurth joins the list of US firms exiting China. The pattern is clear now: firms without a strong cross-border M&A pipeline or a US-listed Chinese client base can no longer justify the cost, and Singapore absorbs the regional work that remains. The practical implication for Swiss companies is less about their external counsel choices and more about what the broader retreat signals: the professional services infrastructure built on assumed US-China integration is being dismantled. Governing law clauses, arbitration seats, and dispute resolution forum choices made in the last five years deserve a fresh look before the next transaction closes.

Reed Smith Opens in Saudi Arabia — Gulf Expansion Is Now Structural, Not Opportunistic

Law.com International

Reed Smith's Saudi Arabia opening joins a list that now includes virtually every AmLaw 100 firm with a credible international practice. The Law.com companion piece on talent wars and red tape is the corrective: the offices exist because the clients are there, not because the unit economics are attractive. For Swiss multinationals with infrastructure investment decisions in the region, the coverage gap is closing — but check whether your preferred firm's Saudi team has the Arabic-language regulatory access your counterparties require, or whether it is a London team with a Riyadh address on its business card.

Hogan Lovells and Cadwalader Build Shared Legal Tech Infrastructure

Law.com International

The Global Legal Tech Alliance announced by Hogan Lovells, Cadwalader, and several other international firms is a joint infrastructure investment — shared vendor negotiations, benchmarked AI tools, coordinated training pipelines. This is not a referral network wearing a technology badge. The point is cost efficiency in AI-assisted document production, which means member firms will reach capability faster and at lower unit cost than those building or buying independently. The timeline for this to show up as competitive differentiation in billing rates is 18 to 24 months. Swiss firms in the same client market should be making the build-buy-join decision now, not in 2028 when the gap is visible on the invoice.

AI at Europe's Borders — The Operational Context Behind the Annex III Delay

SWI swissinfo.ch

Swissinfo documents AI deployments at European borders — facial recognition, behavioural screening, automated document verification — where the legal framework has consistently lagged the operational rollout. This is the ground-level context behind the Annex III postponement: the provisional agreement to push high-risk AI obligations to 2027 was not a concession to caution. It acknowledged that member states were already operating systems that would have required retroactive certification under the original timeline. Swiss providers building in this space should read 2027 as a hard compliance date, not a soft one. The enforcement appetite is there; the delay bought time to build the compliance infrastructure, not to delay starting.

Philippines Opens to Foreign Law Firms — Southeast Asia Is Quietly Liberalising

Law.com International

The Philippines has opened limited practice areas to international law firms, a meaningful step in a jurisdiction that has maintained one of Asia's more restrictive foreign firm regimes. For Swiss GCs with Philippine-facing operations, international firms can now provide direct regulatory advice without routing through a local correspondent. The broader signal: Southeast Asia is moving — incrementally but consistently — toward the model Singapore established a decade ago. Monitor if your Asia footprint runs through Manila, and check whether your current local correspondent relationship remains the right structure.

Trump, Greenland, and the Environment in Which Bilaterale III Is Being Negotiated

Law.com International

Law.com International runs a substantive analysis of the Greenland situation and what US territorial pressure means for the rules-based international order — sovereignty under Art. 2(4) of the UN Charter, the limits of economic coercion, and whether the ICJ retains any realistic role. The Swiss connection is not Greenland. It is the environment in which Swiss neutrality and the Bilaterale III negotiations are operating. A world in which major powers assert territorial claims through economic pressure is one in which dynamic legal harmonisation with the EU looks less like a concession and more like structural hedging. Worth one hour with your public international law counsel before the next board strategy session on geopolitical risk.

The VAG papers are on the desk; the Vermittlervertrag annotations start this afternoon.