Von Tatzenberg's piece today on FINMA's quantum cryptography guidance is the one to read before next week's compliance calendar. The conceptually small step FINMA takes is practically large: it treats the current storage of encrypted data by adversaries — with the intention of decrypting once quantum hardware matures — as a present-tense operational risk finding, not a future scenario. That framing moves post-quantum migration from the "strategic planning" bucket to the "control gap" bucket. Banks that have not yet produced a documented migration roadmap should treat this as a finding in their next ISAE 3402 cycle, not a planning item for 2028.

The second von Tatzenberg piece today is the one that will move the needle in administrative court proceedings. Ferrieri held that bank-data access by Italian tax authorities violated the lawfulness requirement of Art. 8(2) ECHR — the legal framework granted authorities excessive discretion and lacked adequate procedural safeguards; the proportionality limb was not reached because the access failed at the first hurdle. For Switzerland, the operative obligation runs under Art. 1 ECHR: Switzerland must secure Art. 8 rights consistently with the Court's case law; Art. 46 formally obliged Italy as respondent, not Switzerland. The Federal Administrative Court, when reviewing FINMA's decisions on data-disclosure requests from foreign authorities, nonetheless now faces a harder benchmark. The channel requirements in Art. 47 BankG and Art. 271 StGB tell you how to transmit data lawfully. Ferrieri tells you when transmission itself, even if procedurally correct, crosses the line.

The connection to today's quantum piece is worth a minute: the same financial data is simultaneously being demanded under Ferrieri-type legal processes and needing to be protected from future quantum decryption. Same asset, two threat vectors, one compliance calendar.

The third von Tatzenberg article today has the longest tail for Swiss counsel. C-67/25 extends the RT broadcasting prohibition — enacted under EU media sanctions — to individuals who reshare RT content without financial compensation. The question for Swiss-domiciled persons is not purely academic: Swiss platforms with EU users, Swiss employees sharing from EU-accessible accounts, Swiss companies with any subsidiary in a member state. Switzerland adopted the asset freezes against Russia. It did not adopt the broadcasting restrictions. That gap now has a judicial address.

This is structurally parallel to what we documented with DSA Art. 13: the EU continues to assert jurisdiction over Swiss actors through effects doctrine and platform liability rather than formal treaty obligations. Swiss counsel advising media, tech, or communications clients need a framework for this that does not depend on formal Swiss adoption of the underlying rule.

Today's piece on Art. 25 GwV-FINMA is the practical companion to the consultation that closed June 9 — the one FINMA billed as introducing «keine neuen Pflichten». Art. 25 is the clause that puts that characterization under pressure. The board-level risk analysis now requires specific detail on ownership structures, business relationships, and geographic concentration. A cover-page summary approved without substantive board read-through is no longer a defensible process. If your AML function is preparing the Art. 25 document without structured board engagement — not a briefing note, an actual read — the internal workflow needs adjustment before the revised ordinance comes into force. The gap between what the document now requires and what boards typically see is worth a conversation with your chief compliance officer this week.

Von Firn's piece on Helpfind is the deceptively quiet one in today's lineup. The CJEU held that Directive 2009/103 does not preclude national law from permitting the assignment of residual accident-damage claims to professional debt purchasers, and does not preclude the assignee from suing the insurer in its own name. Assignability therefore depends on the domestic law of each member state. The Court also held — and this cuts materially — that a professional assignee does not acquire «injured party» status under the directive, which limits the assignee's procedural and substantive rights vis-à-vis the insurer. For in-house counsel managing an open claims portfolio, reserve levels and settlement timing on every file now need reassessment: the gain of transferability must be priced against the loss of injured-party protections, not simply against the secondary-market rate.

Between April and June 17, FINMA forwarded updates across five separate sanctions regimes: ISIL/Al-Qaida (April), Iran annexes 12 and 14 (April, under the new December 2025 ordinance), Sudan Anhang 2 (June 5), Russia Anhang 8 (June 16), and Hamas/Palestinian Islamic Jihad (June 17). The Hamas/Palestinian Islamic Jihad entry warrants specific attention: many compliance programs have not yet integrated SR 946.231.09 into standard screening workflows alongside the Russia and Sudan instruments. The UNO-track versus country-track distinction is directly relevant here — the Hamas/Palestinian Islamic Jihad ordinance operates on a separate legal basis and country-only screening misses it. If your system batches updates weekly rather than pulling them daily, the June 5–17 window is exactly where a miss appears.

The coalition argument for including cobalt in Switzerland's OR-based due-diligence requirements is worth tracking for battery-supply-chain counsel. Switzerland's existing mineral framework covers tin, tantalum, tungsten, and gold — the 3TG-plus minerals from the Konzernverantwortungsinitiative counter-proposal. Cobalt is the gap. The DRC supplies roughly 70% of global production under conditions that have generated consistent human-rights findings from the UN Group of Experts. If Parliament acts, every Swiss group entity with exposure to battery supply chains — automotive, consumer electronics, grid storage — will need to revisit its due-diligence documentation. The EU CSDDD is already pushing Swiss exporters in this direction through contractual channels, as we noted in our CSDDD piece. Cobalt is not in the NUFG scope currently under consultation — that could change in committee.

The swissinfo review of Swiss foreign bribery enforcement covers the same ground as our pieces on Art. 322septies and the Art. 102 compliance gap: prosecution numbers have improved, but the structural limits run deeper. Art. 102 Abs. 2 StGB creates primary corporate liability for foreign bribery irrespective of whether a specific individual perpetrator has been identified — the enterprise is liable for organisational deficiency, not because a named person's act was attributable to it. The structural gaps the OECD Working Group on Bribery has flagged across three review cycles are the CHF 5 million maximum fine cap and the breadth of the organisational-deficiency standard. If your compliance program is calibrated to Switzerland's improving prosecution rate rather than to those structural limits, it is built around the wrong benchmark.

Law.com's survey of five PE plays in law firm financing is US-focused, but the question reaches Geneva and Zurich through two channels. First, Swiss-market firms advising PE-backed portfolio companies may now be financed — however indirectly — by capital related to those same PE funds: the Standesregeln and cantonal Anwaltsgesetze were not written with this scenario in mind, and the disclosure obligations do not currently surface the relationship. Second, Switzerland's formal restriction on outside capital in law firms is stricter on paper than in practice: PE money can flow through loan structures, affiliated advisory entities, or co-venture arrangements that technically comply while functionally creating the same alignment concerns as equity ownership. There is no disclosure regime that would make this visible to clients. That gap will not stay invisible indefinitely.

Cross-border mandates with China-adjacent elements that require a neutral jurisdiction, international arbitration outside CIETAC, or sanctions advice that cannot be given from a Beijing-proximate office are routing in part through Geneva and, to a lesser extent, Zurich. Whether this is a durable structural shift or a temporary deflection depends on how quickly Singapore, Stockholm, and Paris absorb the same flow. Switzerland's continued use in commercial disputes between parties who distrust each other's court systems is a structural advantage that has not meaningfully eroded — and the current geopolitical configuration, with the RT ban (C-67/25) and investment-screening rules pulling Switzerland and the EU into closer alignment, makes strict-neutrality venues more valuable, not less.

The swissinfo explainer on Swiss investment screening is accurate on the political context — nervousness about state-adjacent acquisitions in dual-use technology — but undersells the legislative outcome. We covered the trajectory in our piece on the Investitionsprüfgesetz: what came out of parliamentary committee is meaningfully stronger than the "light touch" originally pitched, with broader sector coverage and tighter notification timelines. If you have a transaction currently in due diligence involving a Swiss target in infrastructure, critical technology, or defense supply chains, and your deal timeline runs past the law's entry into force, the review risk needs to be in the models now — not on the closing checklist.