Dr. iur. Servatius von Tatzenberg's piece, published on June 2, answers the question that has been hanging since October 2025: whether your company is inside the Art. 74b ISG catalogue in the first place. The sanction architecture under Art. 74h — up to CHF 100,000 — has been live since then; the scope question has remained underspecified in public BACS guidance. Our May analysis mapped the penalty mechanics and the Art. 74e trigger; that piece maps the threshold. Circulate both to IT security and legal ops together — the 24-hour clock and the question of who it binds are not separable problems.

Servatius von Tatzenberg's piece today covers the cycle that is now active. The 30% board / 20% executive thresholds under Art. 734f OR apply only to listed companies; the comply-or-explain obligation runs in the 2026 annual report. Disclosure of the gap is not an explanation — the OR requires a concrete measures plan. "We are aware of the shortfall" will not hold. Companies that have not embedded a diversity mandate into their governance structure should do so before the annual report is signed. The disclosures are public, and the first cohort to file a blank explanation will not be invisible.

The second Servatius von Tatzenberg piece today picks up the state aid thread from our May 24 framework article. The June 2 article's core ask is an inventory and classification exercise: which cantonal subsidies your company receives fall within the scope of the forthcoming BHÜG, and whether those arrangements would survive scrutiny by WEKO — the Bundesgericht as appeals instance; the EU-side review channel is subsidiary. The state aid exposure for companies receiving cantonal subsidies carries a five-year build-up transitional period plus a further year for stock review — the article opens "Zeit bleibt allerdings," and that framing should be read as an instruction to start the inventory now, not a reason to defer.

Casimir von Firn's EMFA piece today maps an instrument most platforms have read as an editorial-independence text and set aside. The compliance architecture runs further. The interaction with the DSA representative obligation for Swiss platforms without an EU seat is the most immediate issue — EMFA stacks on DSA, it does not substitute for it. If your platform has not yet closed the DSA exposure analysis, EMFA is another reason to move it up the queue, not a separate workstream to open later.

The FINMA consultation on the partial revision of the GwV-FINMA closes in six days. The provisions we covered in May — Art. 9b and Art. 65(2) on beneficial-owner transparency, and Art. 30 on sanctions and embargo compliance — are mapped in that analysis. In our reading, the combined evidentiary direction of Art. 9b and Art. 65(2) moves the verification standard from "document what the client disclosed" toward "document why the disclosed structure is plausible" — that characterisation is this publication's analytical gloss on the clause structure, not a direct quotation from FINMA's consultation materials; readers should verify the framing against the explanatory memorandum. A formal response costs little; it shapes how FINMA reads the regulation when it publishes the final version.

The May 7 Grand Chamber judgment in C-747/22 (INPS) declared incompatible with EU law an Italian requirement for continuous residence as a threshold for social assistance and employment access, finding it indirectly discriminatory against beneficiaries of subsidiary (international) protection status under Directive 2011/95/EU. The proportionality analysis rejected the residence condition as incompatible with the integration objectives of that Directive; formal application has been referred to the national court. The case arose under Italian law but the principle applies across all Member States. For Swiss in-house counsel with EU subsidiaries: any benefit-entitlement or employment-access policy that gates eligibility on residence duration — rather than on employment relationship or contractual status — deserves a review specifically for workers holding international protection status under Directive 2011/95/EU. The judgment is not a surprise, but its directness on what the Directive's integration objectives require of Member States is.

Three annexe updates that monthly-cycle screening will have caught, but weekly-cycle shops may have processed unevenly: Sudan under SR 946.231.18 (May 1), ISIL/Al-Qaeda under SR 946.231.08 (FINMA notice April 1), and Iran annexes 12 and 14 under SR 946.231.143.6 (FINMA notice April 14). The ISIL list is the most operationally pointed — it runs on the UN 1267 track and, as we explained in May, country-of-origin screening will not catch it. If your last full-list verification predates March 31, run it again before the week closes. None of these updates is dramatic in volume; all of them are binding.

Hunton Andrews Kurth has announced a Beijing closure; K&L Gates has consolidated its Beijing practice into Shanghai, retaining both its Shanghai and Hong Kong offices. Pinsent Masons moved in the opposite direction in March 2026, forming a joint venture in Qianhai. The divergence is informative: the generalist international footprint in mainland China is contracting, while firms making structural commitments are deepening. For Swiss in-house counsel who rely on international firms for China onshore legal opinions and deal work — the panel coverage question is worth asking before a transaction forces it. Knowing which of your preferred firms is in the commitment column versus the withdrawal column is due diligence on your own external counsel setup.

Swissinfo has documented what is already deployed at EU entry points: biometric screening systems that sit explicitly in Annex III of the AI Act as high-risk applications. The 2027 deferral reached in the May Council-Parliament talks is a provisional political accommodation pending formal co-legislative adoption — the risk classification, conformity-assessment obligations, and transparency requirements remain in the text unchanged regardless. For Swiss suppliers to EU border agencies, 2027 is the compliance date, not the preparation start date. The bilateral III connection is direct: dynamic alignment would eventually draw Switzerland into tracking AI Act amendments on an ongoing basis — one more reason compliance monitoring infrastructure needs to be built for EU law generally, not only for the named agreements.

A coalition including Hogan Lovells and Cadwalader announced a Global Legal Tech Alliance — a collaborative forum for AI standards, joint solution development, and training across member firms, not a shared operational platform for document handling or matter management. The in-house angle, where there is one, is narrower: the broader trend of external counsel adopting shared or AI-augmented tooling raises a question that engagement letters and data processing agreements signed before that migration may not answer. When your external counsel moves onto shared or AI-augmented infrastructure, the terms governing your matter documents and privileged correspondence need to be current. Whether GDPR Art. 89 secondary-use constraints extend to platforms processing client matter data is this publication's inference from the broader AI-tooling landscape, not a claim the announcement grounds — verify your own data processing agreement before raising it with counsel.

FINMA will relocate its Zurich office from Wasserwerkstrasse 12 in the city centre to Zürich-Oerlikon in November 2026. The Bern headquarters is unaffected. If your institution routes FINMA correspondence, regulatory submissions, or physical deliveries through the Zurich address, update the register before November 2026. The move was announced in February; it is worth a five-minute check with your regulatory affairs team to confirm the new address has been captured.