WBF updated Annex 2 of the Sudan ordinance on 5 June. We flagged the mechanics of this exact lag back in May: the Swiss list mirrors the EU's with a gap you can set your watch by, and a screening process built around "we match the EU list" will always be running slightly out of date. Nothing new here except the reminder that the gap is structural, not a one-off.

SECO updated SR 946.231.08 on 14 July — the same UN 1267 list we wrote about in the spring. Names on this one bind the moment the UN Sanctions Committee acts, independent of any country-level screening you're running. If your onboarding checklist treats this list as "covered by" a broader jurisdictional screen, it isn't — check the actual name match, not the flag next to the passport.

Another Annex 8 revision under the Russia ordinance, this one dated 16 June. Each of these is, technically, a fresh "change in law" event for anyone with a MAC clause tied to sanctions exposure — the point we made in the piece on the 20th package. The burden of proving materiality still sits with whoever wants out of the deal, and a routine annex tweak like this one almost certainly won't clear that bar on its own.

SECO amended the Taliban sanctions list on 1 May. One line in the register, worth thirty seconds against your screening feed and nothing more.

WBF amended the annex to the 10 April 2024 ordinance on 17 June — FINMA's own notice doesn't name the regime, which tells you something about how far down the sanctions-infrastructure list this one sits. If your screening vendor auto-ingests SR numbers rather than headlines, you're fine. If a human has to notice the FINMA notice first, you're not.

A follow-on update to the Iran ordinance we covered after its December total revision — proof that a total revision isn't a reset, just a new baseline that keeps getting amended at the annex level like everything else.

The consultation FINMA opened on 12 May closed on 9 June, and we spent the run-up on exactly what it would and wouldn't change: no new duties, on paper, but three clauses that quietly move the burden of proof on beneficial-owner transparency. Now it's in FINMA's hands. Nothing to file yet — but worth a calendar note for when the revised text lands, because the comment period is the last point anyone outside FINMA gets to argue about where that burden sits.

The pressure to widen the NUFG's commodity scope keeps building, and cobalt is the test case — a mineral the EU's own conflict-minerals framework already treats as sensitive, which we noted was one of the ways the CSDDD gets to Swiss exporters before the NUFG does. If your supply chain touches battery-grade cobalt, the contractual obligation may already be there regardless of how the Swiss legislation ends up scoped.

Mainstream coverage catching up to what deal lawyers have been pricing into term sheets since spring — the Investitionsprüfgesetz was sold as light-touch, but the parliamentary debate produced something with real teeth, which we walked through in this piece. Read together with today's cobalt story, the pattern is the same one twice: Switzerland importing more foreign-facing scrutiny into domestic law than the "we're different from the EU" framing suggests, on capital as well as on supply chains.

This is the story behind the story we're publishing today: whether a sponsored chair is a gift, and if so, whether it falls under the same disclosure logic as any other undisclosed advantage to an official or institution. Full analysis from Dr. iur. Servatius von Tatzenberg later today — worth the wait if your organisation funds anything at a Swiss university. Separately, and unrelated except in timing: he's also got a piece out today on where Aarhus Article 9(3) leaves standing for Swiss emitters after KlimaSeniorinnen. Two very different fights, same byline, same publication day.

Old news by our standards — we covered the dispatch itself the day it landed, both what FINMA said was still missing and the three-part shape of the reform. FINMA's welcome statement adds nothing beyond confirming it's on board with its own wish list. Next stop is the parliamentary committee, which is where the real fights start.