FINMA logged six separate sanctions-annex updates since mid-May: ISIL/Al-Qaida again in July, Russia's Annex 8 in June, plus Sudan, the Taliban list, and Iran. None of them individually is a story. Together they're the reason automated screening beats a quarterly manual review — as we wrote in May, the UNO-track lists move faster than most banks' name-matching cycles.

The pattern worth tracking: the gap between an EU listing and its Swiss mirror keeps running two to three weeks, same as with Sudan's Annex 2 in February. If your screening vendor claims same-day EU coverage, ask what they actually do with that gap.

The AMLO-FINMA consultation that launched 12 May closed 9 June, as flagged when we walked through the three clauses that shift the burden of proof on beneficial-ownership documentation. FINMA hasn't published a submissions summary yet. If your compliance team filed comments and hasn't heard back, that's normal — expect the revised circular closer to year-end.

FINMA's statement on the Federal Council's Banking Act dispatch reads warmer than the dispatch earned it. We counted four instruments FINMA asked for and didn't get, early-intervention powers chief among them — and the capital-and-accountability package still needs to survive parliamentary committee. Third TBTF attempt, same three fault lines.

We already went through why the press release undersells the actual audit mandate buried in supervisory communications 05/2025, 01/2026 and 02/2026. If you only read the April summary, go back for the annex.

The digital fraud circular from April is still generating compliance memos, and rightly — we've argued fraud KPIs belong on the compliance board's agenda, because Art. 146 StGB fraud is a predicate offence to money laundering, not just an operational nuisance. Today's piece on where fraud defence actually sits in Art. 12 BankV covers the mechanics. Dr. von Tatzenberg's piece running later today on FINMA's quantum guidance draws the same line under cryptographic inventory — expect the two circulars cited together in board decks by autumn.

FINMA's liquidation order against MBaer Merchant Bank survived the bank's appeal with suspensive effect intact — a genuinely unusual outcome, as we covered in May. What didn't survive: FinCEN's primary-money-laundering-concern designation from Washington, which runs on its own clock regardless of what the Swiss appeal court decides. Two jurisdictions, two timelines, one bank caught between them.

The Federal Council's 25 February adoption of the 19th EU sanctions package against Russia and Belarus is the baseline we described in "vom Sonderweg bleibt der Vollzug" — Switzerland's independence here is procedural, not substantive. The 20th package, adopted 22 May, is the one that actually triggered MAC clauses in M&A paper, as we wrote last week. If your contract review only flagged the 19th, check the 20th too.

Swissinfo's writeup of Proton's win reads like a single headline, but the ruling — BVGer A-5373/2020, which we covered — took five years to land and sets the line for every provider of derived communication services, not just Proton. The proportionality test now has teeth; providers who assumed VÜPF obligations applied uniformly should re-read Art. 8 more carefully.

Swissinfo frames the EU's supply-chain rules as a looming threat to Swiss exporters. We'd push back on the tense: as we argued in "CSDDD vor NUFG", the binding already happened, through contract clauses EU counterparties inserted long before the Federal Council opened its own NUFG consultation on 1 April. Casimir von Firn's piece running later today goes further — the EU's forced labour regulation reaches Swiss exporters with no due-diligence threshold at all, unlike CSDDD's revenue cutoffs. Read that one before your next supplier audit.

Swissinfo asks the obvious question about the Investitionsprüfgesetz. Our answer, from the parliamentary record: it isn't really "light touch" anymore — as we wrote in May, deliberation produced a real screening risk that belongs in the term sheet stage of any inbound M&A deal, not in a post-signing compliance memo.

The European Law Blog's read on Commission v Hungary is worth ten minutes even without an EU-law docket: the CJEU let "values" under Article 2 TEU outweigh a member state's "national identity" defence under Article 4(2) — a balancing test the Court had mostly avoided spelling out. It has no direct Swiss application yet, but it's exactly the kind of jurisprudence pulled into scope through dynamic rule adoption under Bilaterale III, which binds interpretation to the ECJ's evolving case law, not a frozen snapshot. Read it now so it isn't a surprise citation in three years.

2C_46/2024 keeps resurfacing in the case-law feeds, five months after the Bundesgericht decided it — that usually means someone just cited it in a brief. The ruling closed the subcontractor workaround for gig platforms under cantonal labour rules; we mapped the mechanics in "Chaskis-Schema: Plattform-Diligence wird kantonal". If your platform operates in Romandie and still routes drivers through a subcontractor layer, that door closed in February.