SR 946.231.08 runs on the UN 1267 track, not the EU-mirroring track most sanctions desks are built around — which means a name binds in Switzerland the moment the UN committee lists it, full stop, no Federal Council ordinance in between. We wrote about exactly this gap in May: teams that screen against the EU consolidated list and treat Switzerland as a downstream mirror miss UN-track listings by design, not by error. This is the second amendment to the same annex since April. If your screening vendor's update cadence is monthly, you have already had a gap.

WBF has amended Annexes 12 and 14 of the 12 December 2025 Iran ordinance — the total revision that, as we covered at the time, replaced the pre-Vienna framework wholesale. This is routine maintenance of the new regime, not a policy shift. Worth noting only because it confirms the new ordinance is being actively kept current, unlike its predecessor, which sat stale for stretches. Don't let your Iran screening rules revert to the old annex numbering out of habit.

Beyond ISIL and Iran, this stretch also brought updates to the Taliban list (SR 946.231.07, mid-April) and, about two months later, Annex 2 of the Sudan ordinance (SR 946.231.18, 4 June) and Annex 8 of the Russia ordinance (SR 946.231.176.72, 15 June). The Sudan and Russia amendments landed within the same fortnight — that pairing, not a four-instrument sweep, is the actual signal: WBF and SECO ran two active regimes through the same cycle back to back. A reported fourth update, to the consolidated list under the 10 April 2024 ordinance (SR 946.231.09), we could not confirm for this window — the only 2026 amendment on record for that instrument dates to 18 February, so it stays out of the count rather than getting repeated on trust. If your compliance team patches screening lists one regime at a time as news breaks, the Sudan/Russia pairing is the reminder to run a batch refresh instead of waiting for the next headline.

The partial revision of the AMLO-FINMA went to consultation on 12 May and the window shut on 9 June. We flagged at the time that "no new duties" undersold three clauses that quietly shift the burden of proof on beneficial-ownership transparency. FINMA hasn't published a response to comments yet. If you filed anything during the window, now is the moment to check whether it landed — responses to consultations this size typically surface within eight to ten weeks, which puts a published version somewhere around mid-August.

The dispatch the Federal Council adopted on 22 April moves TBTF reform into Parliament's hands, and FINMA's welcome statement reads warmer than its substance — the regulator itself flagged, as we detailed in both the dispatch analysis and the broader TBTF piece, that capital, accountability and supervisory instruments in the bill still fall short of what FINMA asked for. The bill is now with the committees. Watch the National Council's economics committee schedule for autumn — that's where the capital number gets fought over line by line.

The 21 April press event bundled the 2025 annual report, the enforcement retrospective and two speeches — but the digital-fraud supervisory notice wasn't part of it: FINMA published that one as a standalone supervisory notice twelve days earlier, on 9 April. We went through the gap between the press summary and the underlying documents in this piece. A separate crypto-custody notice, 01/2026, exists too, but it dates to 12 January and isn't tied to this event either — don't file it under the April conference. If your compliance lead only read the press release, they read the wrong document, and now know which other ones to pull.

Supervisory notice 02/2026 doesn't pick a lane: FINMA ties digital fraud explicitly to both Art. 12 BankO operational risk management and the AML obligations under Art. 9 AMLA, with online identification and institutional governance sitting in the same document as fraud detection. That matters because we've argued fraud is a predicate offence to money laundering under Art. 146 SCC — the guidance now confirms FINMA reads it the same way, rather than filing fraud purely as an operations problem. Two angles worth reading together: where the notice sits in the operational-risk framework and why your fraud KPIs belong at the compliance board anyway. The practical read for your org chart: don't let this land solely on IT risk or solely on the MLRO — the guidance expects both functions working from the same fraud data, not trading it across a wall.

FINMA's liquidation order against MBaer became final not because a court upheld it, but because MBaer withdrew its complaint on 27 February 2026 — one day after FinCEN's designation of the bank landed in Washington. The Swiss proceeding never reached a ruling on the merits; the US action made the appeal moot before the court had to decide anything. We covered the sequencing here. The lesson for anyone with a US correspondent relationship holds regardless of the correction: a Swiss appeal buys you time in Switzerland. It buys you nothing in Washington — and here it didn't even buy much time, just a single day.

The Federal Administrative Court ruling in A-5373/2020, dated 13 October 2021, is the one we called a five-year line in the sand back in May — but the mechanism was service classification, not a proportionality test. The court held that ProtonMail is a provider of derived communication services (AAKD), not a telecommunications service provider (FDA), and that classification is what narrowed its surveillance duties under the Federal Act on the Surveillance of Post and Telecommunications. Full argument here. The reason it's back on the desk now, and not filed under case law from five years ago, is the current surveillance ordinance consultation — Bern is revisiting exactly the category lines this ruling drew. If you run a Swiss-domiciled comms product and haven't mapped which category you fall into, that consultation is the reason to do it now rather than after a request lands on your desk.

The framing question answers itself once you read the parliamentary file: "light touch" was the marketing, and what emerged from committee is a real gate. We went through where the actual risk sits — in the term sheet, not the closing memo. If a foreign-controlled counterparty is in your cap table or your acquisition pipeline, this stops being a policy-page story sometime in the next two quarters.

Two questions, one file. Swissinfo's piece on the enforcement gap pairs naturally with the perennial "is a Rolex bribery" question — and both come back to the same answer we gave in the Art. 102 para. 2 SCC piece: the gap is in the compliance programme, not in the statute. Switzerland doesn't lack a law against foreign bribery; it lacks organisations that can show they tried to prevent it. And the gift-threshold question has the same shape — Art. 322septies SCC has no franc figure, only a link to an official act. If your gifts policy has a number in it, that number is doing less legal work than you think.

Four go up today and none of them are small. Dr. von Tatzenberg on when AML and fraud scoring crosses into a prohibited crime-risk model under Art. 5(1)(d) EU AI Act. Herr von Firn on the 30 June deadline for the 40% board quota under Directive (EU) 2022/2381 — including for the EU-listed subsidiary of a Swiss group, which is the part everyone skips. Von Firn again on CBAM from 1 January 2026: the Swiss goods are exempt, the Swiss seller acting as importer is not. And Dr. von Tatzenberg on C-713/23, where the spouse in your benefits matrix stops following national civil-status law. Read them as they land.