The consultation on FINMA's partial GwV-FINMA revision closes 9 June. If you work at a bank, securities dealer, or asset manager regulated under AMLA and have not read the draft, today is the practical deadline. The three clauses that matter most — beneficial-ownership transparency, risk-category documentation, and the extended PEP-perimeter trigger — are mapped in our 27 May piece; the evidentiary consequences of each are in the 16 May companion. FINMA's framing — "no new obligations" — is technically accurate in that the underlying duties predate the revision. What the revision changes is who carries the proof burden when something goes wrong. That is not a technicality worth filing under "legal nuance."

Today's piece by Servatius von Tatzenberg — on the Wendelspiess conduct-rule bans — answers a question that many advisers and senior managers have been quietly filing under "probably not my problem." The bans operate under FINMA's conduct-rule toolkit, not under the licensing regime, which means the absence of a personal FINMA licence is not a shield. If your firm's compliance narrative still treats FINMA enforcement exposure as institutional rather than individual, that narrative is running on assumptions that Wendelspiess has now tested. The same annual media conference that surfaced the Wendelspiess result confirmed individual accountability as a standing priority, not a crisis response. Fifteen minutes with your employment counsel this quarter is a proportionate reaction to this morning's reading.

Casimir von Firn's piece today — on FINMA's new portfolio-management guidance — has a practical punch that is easy to underread. The guidance reframes product-selection documentation from a quality practice to a suitability defence: the examination question is not "did you select an appropriate product?" but "can you show that you assessed suitability at the moment of selection?" The shift from ex-post explanation to ex-ante documentation is the same structural move the GwV-FINMA revision makes in AML. Both land this week. If your compliance and investment teams read them separately, have them read them again together — the direction is coordinated.

Today's analysis by Servatius von Tatzenberg — on the CJEU's clarification of the European Account Preservation Order threshold — is the piece to put in front of your litigation and treasury teams simultaneously. The court has confirmed that the EAPO mechanism is evidentiary, not numerical: a creditor seeking to freeze an EU account across borders must show, on the facts, that recovery is at genuine risk. A balance amount alone does not reach the threshold. For Swiss creditors with EU-debtor exposure, and for Swiss banks receiving EAPO orders from EU courts, the paper quality behind any freeze application matters as much as the underlying claim. The EAPO Regulation 655/2014 has been operational since 2016; this ruling is the first significant CJEU word on what the evidentiary floor actually is.

Casimir von Firn's piece today — on three mechanisms from the January 2023 OR revision that remain underused — matters most for companies whose AGM season is not yet finished or who are preparing an autumn extraordinary meeting. Electronic participation, updated circular-resolution thresholds, and simplified share-capital provisions are all live in law; the blocker in most cases is simply that the enabling bylaw amendments have not been brought to shareholders. The piece maps the statutory language each amendment requires. If this is news to your corporate governance team, the drafting starts this week — not next quarter.

The third piece today from Casimir von Firn — on how Art. 100 OR treats imported limitation-of-liability clauses — closes a gap that appears in almost every cross-border services or M&A negotiation involving a Swiss party. Swiss mandatory law voids complete exclusions of liability for gross negligence and intentional conduct regardless of the governing-law clause, where the breach connects to Swiss territory. Importing a standard English or US cap-and-exclude structure and relying on the governing-law clause to hold it is gap management, not risk management. The gap is wide. The 25 May piece on Art. 100 Abs. 1 is the companion read for the mechanics of what is void and what can still be saved with a cap rather than a full exclusion.

The Federal Administrative Court confirmed MBaer Merchant Bank AG's liquidation after the interim suspension was lifted. The procedural history is in our May piece. What the case contributes to this week's reading is the FinCEN dimension: when US Treasury designates a Swiss institution as a primary money laundering concern, access to US dollar correspondent banking collapses faster than any Swiss court can move. The Swiss regulatory response, measured in months, is not calibrated to a correspondent-banking crisis that plays out in days. Swiss banks with meaningful US dollar flows should have a tested contingency protocol for that scenario — not a FINMA-call plan, but a correspondent-bank-calls-before-FINMA plan.

FINMA has posted routine annex updates for Sudan (SR 946.231.18, effective 1 May) and Iran (Anhänge 12 and 14 of the 12 December 2025 ordinance, effective 14 April). Standard list management. The structural point worth repeating: Switzerland runs 15 to 20 days behind EU updates on average — the 23 May piece on the sequential lag documents this across multiple regimes. If your screening workflow runs SECO lists only, that gap is your exposure window. Dual-feed screening — SECO plus EU simultaneously — is not gold-plating at this point. It is gap-closure.

We mapped Girard's appointment and its Art. 60 BankV implications in the 23 May piece. Two months in, the BankG Botschaft from April gives him a legislative runway on TBTF capital and individual accountability provisions — the 28 May analysis has the detail. The practical question for bank governance and treasury teams is whether Girard accelerates the recovery-planning examination cycle for mid-tier institutions, which received less intensive scrutiny under his predecessor. His résumé — recovery and resolution specialist — makes that a reasonable expectation rather than speculation. If your institution's recovery plan has not been reviewed internally this year, the review starts before FINMA asks for it, not after.

Several major firms — Hogan Lovells and Cadwalader among them — have announced a Global Legal Tech Alliance structured around shared AI tooling investment. For in-house counsel, the technology details are secondary. The pricing signal is the interesting part: when BigLaw shares AI infrastructure costs rather than differentiating on them, the per-matter cost of AI-assisted drafting and research compresses toward a common floor. That floor is already below what a well-equipped in-house team operates at for routine work. The open question is whether shared tooling accelerates the moment at which external counsel becomes the exception rather than the default for AI-assisted legal tasks — or whether it just changes the billing label on work that looks identical from the outside.

Hunton Andrews Kurth has shuttered its China mainland office, joining a growing queue of international firms whose economics no longer work in a market where deal flow has not recovered to pre-2021 levels and regulatory friction runs in both directions. At the same moment, Pinsent Masons is forming a joint venture with a Chinese commercial firm in Qianhai, betting that a regulated partnership structure survives the environment that a branch office cannot. Both positions are rational responses to the same facts — the disagreement is about which structure holds. For Swiss in-house counsel managing transactions with China exposure, the practical consequence is that external-adviser selection for PRC-connected work is becoming less stable. Build in longer lead time on counsel qualification, not shorter.