The ISIL/Al-Qaida list (SR 946.231.08) got its mid-July refresh from SECO. Over the past two to three months the Sudan annex (SR 946.231.18), the Taliban list (SR 946.231.07, amended late April), and the Russia ordinance (SR 946.231.176.72) all picked up amendments too. None of these will make a headline anywhere else. All four belong on your screening vendor's ingestion log this week, not next.

The pattern matters more than any single name added or removed: WBF and SECO now amend these annexes roughly every three to five weeks, faster than most in-house screening cycles run. If your compliance calendar checks sanctions lists monthly, you are structurally behind the regulator's own cadence.

Easy to miss precisely because the underlying ordinance (SR 946.231.143.6, Annexes 12 and 14) was already a full rewrite — see our piece on the four articles that replaced the JCPOA playbook. The annexes are where the actual names live, and they move independently of the framework everyone read once and filed away.

Worth flagging why this is in today's roundup at all: the aggregator resurfaced a ruling that isn't new. The Bundesverwaltungsgericht decided A-5373/2020 on 13 October 2021, and we covered it in detail back in May — the piece on VÜPF and derived communication services. Proton never won a special dispensation in that proceeding; the court held, and still holds five years on, that proportionality is a condition precedent for stretching an ordinance written for phone companies onto encrypted-mail providers, not background music Bern can wave away by administrative fiat. Nothing changed this week — the gap, if you have one, predates this news cycle by five years, not five days.

The NUFG consultation opened April 1 and runs on its own Swiss timeline, but the substantive fight over what gets covered is happening in commentary like this — cobalt is the mineral where the human-rights case is strongest and the current draft's scope is weakest. Worth reading before your own submission is due.

Nothing here changes the read from our piece on where the screening risk actually sits in a term sheet — sold as light-touch, drafted otherwise — but it's a clean primer if you need to explain to a foreign acquirer's counsel why Switzerland, of all places, is doing this now.

Context for anyone who read our piece on the deferred Annex III biometrics deadline: the deferral to 2027 was a reprieve for the compliance deadline, not for the market. Procurement keeps moving regardless. A Swiss vendor selling into this space has eighteen extra months to get the high-risk documentation right — not eighteen months to ignore it.

Consistent with our own read on Art. 102 para. 2 and the compliance-programme defence: the enforcement numbers are up, which sounds like progress until you notice the gap is structural, not a matter of prosecutorial willpower. A company's Art. 102 defence still lives or dies on whether it can show an organised programme before the fact, not after.

Short version, and we said it first: Swiss exporters are already bound by CSDDD through their contracts with EU counterparties, well ahead of whatever the NUFG consultation eventually produces — see our piece from May. Good explainer to forward to a business unit that still thinks Swiss law is the only law that applies to a Swiss company.

The comparison is doing real work in Brussels commentary now, and it should worry anyone treating Bilaterale III ratification as a formality: the dynamic rule-adoption mechanism is precisely the piece that split British opinion for a decade. Our note on what the dynamic rule-taking already requires of your legal department today stands regardless of how the referendum politics shake out — the obligation runs from the treaty text, not from public sentiment.

Not a Swiss story directly, but useful for any in-house team relying on the EU's "shared values" framing to justify a compliance posture: the Court still hasn't drawn a clean line between the Union's values clause and a member state's constitutional identity, and that ambiguity is exactly where national derogations get argued. Relevant background if your CSDDD counterparty due diligence touches a jurisdiction where this fight is live.

A narrower read for the specialists: procedural rights and fundamental-rights protection don't always pull in the same direction in recent ECJ case law, and Bouskoura is this term's clearest illustration. File it next to two rulings getting the full treatment elsewhere on this site today — Casimir von Firn's pieces on C-474/24 NADA and C-247/23 Deldits — all three wrestle with how much process is owed before a right gets vindicated.