Today is the last day to file comments on FINMA's partial revision of the Anti-Money Laundering Ordinance. The revision was publicly framed as introducing no new obligations; as we argued in May and in the clause-by-clause analysis, the three ownership-transparency provisions shift where the documentation burden falls at onboarding — not whether it applies. Institutions with pending AML programme reviews should flag the revised sequencing to compliance counsel before the ordinance takes effect. After midnight, the consultation record closes.

Servatius von Tatzenberg's piece today traces how FINMA has accumulated four Aufsichtsmitteilungen in a single supervisory window — crypto custody (AM 01/2026), digital fraud (AM 02/2026), product suitability (AM 03/2026), and AML risk analysis (AM 04/2026) — without packaging any of them as a Rundschreiben subject to the industry consultation that Art. 7 FINMAG was designed to guarantee.

The supervisory consequence is not theoretical: examination firms operate under Art. 24 FINMAG and measure institutions against what FINMA expects. What FINMA expects is now in the guidance notes. The exam standard is set; the consultation was skipped. Today's GwV-FINMA deadline is, in this light, an interesting juxtaposition: FINMA formally consults on one instrument while setting the operative compliance baseline through four others that it did not consult on at all.

FINMA AM 03/2026 on product selection and suitability confirms escalation cases more than doubled in each of the last two years. The shift is not in the law — Art. 12 FIDLEG has not changed. The shift is in how examination firms are measuring it. Today's article sets out the operative requirement: the suitability justification must be dated at the moment the product enters the discretionary mandate, not reconstructed afterwards. That is the distinction being caught in 68 cases and counting.

FINMA's Aufsichtsmitteilung 04/2026 extends the 2023 AML risk-analysis guidance to FINIG-licensed asset managers with an explicit methodological instruction: generic risk catalogues are what got flagged in 2023, and they are still being flagged now. The examiner enters through the risk analysis, not through the customer file. An institution whose risk analysis does not articulate explicit exclusions matched to its actual business model is starting the examination cycle already behind. Short and concrete — the article covers what FINMA said was missing in 2023 and is still missing in 2026.

FINMA closed its enforcement proceedings against Wendelspiess Partners AG on 3 June and imposed multiyear Berufsverbote on two responsible individuals under Art. 33 FINMAG for serious violations of FIDLEG conduct rules — principally the total absence of suitability checks. Over 400 clients, most assessed as having limited financial knowledge and a risk-averse profile, had substantially all their assets channelled into a single fund in which Wendelspiess and its principals held their own positions. CHF 83 million, minimally diversified, near total-loss exposure at year-end 2024. The clients were not told.

The structural point the article draws from this: the advisory process is now a personally sanctioned duty of the individuals who run it, not just an institutional obligation. Art. 33 FINMAG is not a corporate fine — it follows the person. Combined with the escalation figures in AM 03/2026 above, this is the trajectory: examination catches the missing documentation, enforcement follows the responsible individual.

The standard e-banking clause shifts losses from fraudulent payments onto the customer. Art. 100 Abs. 1 OR blocks this where the bank's own gross negligence is the cause. Today's article makes the structural argument: because FINMA AM 02/2026 raised the control standard against which courts will measure what a bank should have detected, the clause transfers less liability in exact proportion to how much the standard has risen. The clause has not been rewritten; the benchmark against which a court reads "gross negligence" has been. That is a liability exposure that will show up in disputes, not in contract reviews.

FinCEN designated MBaer Merchant Bank AG as a primary money laundering concern under 31 U.S.C. §5318A in February and proposed the fifth special measure. The practical consequence — covered in today's piece — is that every US bank receiving the eventual final rule is required to document that it carries no MBaer flows, and that proof burden cascades through every correspondent link in the chain. Swiss institutions that have never been a party to the proceeding, never had a direct MBaer relationship, and never processed a flagged transaction now carry the documentation obligation simply by being in a correspondent chain that could theoretically reach MBaer. That is not a future risk; it is an active due-diligence item for correspondent banks today.

Sudan (SR 946.231.18, 5 June), Taliban (SR 946.231.07, 1 May), ISIL/Al-Qaida (SR 946.231.08, April): three separate ordinances, three separate publication cycles, three discrete re-screening triggers in five weeks. Von Tatzenberg's piece today argues that institutions treating SECO updates as reference-data refreshes rather than active screening events carry a latent compliance gap — because the obligation attaches at each publication date, an update-SLA that lags SECO's cadence leaves a documented gap that no quarterly re-screen cures. The Sudan update last Thursday is the freshest illustration of a pattern that is running faster than most screening protocols are designed for.

If you need to process a payment that the Ukraine sanctions have blocked, Art. 15 Abs. 5 of the Ukraine-Verordnung provides the mechanism — a prior authorisation from SECO. The article corrects a common misreading: institutions searching the Embargogesetz for a general release provision find only the criminal norm. The release is in the secondary ordinance, it requires advance approval, and it must be in hand before the payment moves. Processing first and applying for retroactive authorisation is not a recognised path.

The EU General Court on 3 June upheld Meta's gatekeeper designation for Messenger and annulled it for Marketplace. The Marketplace designation failed because Meta changed the product on 31 July 2023, before the Commission's 5 September designation — and the Commission did not account for that change in its reasoning. The article draws the operative point for anyone monitoring DMA exposure: the gatekeeper analysis is taken at the designation date, using the product as it existed then. A product that crosses the threshold thresholds but is meaningfully changed before designation has a factual argument. The obligation to document what the product looked like on the relevant date is now a material fact for any threshold-adjacent service.

The EuGH held in C-198/24 (Mr Green, 21 May 2026) that the "actual danger" standard for a European Account Preservation Order under Art. 7 Abs. 1 Verordnung (EU) Nr. 655/2014 does not require recent debtor conduct. A creditor can rely on behaviour from years earlier and on a debtor-state law that obstructs enforcement to establish the risk of asset dissipation. The Mr Green scenario — a Maltese online gambling operator defying an Austrian enforcement title while holding accounts in Ireland, Luxembourg, Malta and Sweden — is specific, but the principle is broad. Any EU-based entity with accounts in multiple member states and an adversarial creditor relationship anywhere in the EU has increased exposure to cross-border account freezes based on old conduct. Today's piece covers the evidence standard and what changes for creditors and debtors alike.

The 24-hour reporting obligation under Art. 74e ISG has been penalty-backed since October 2025. Today's transaction-focused piece makes a point that has not yet surfaced widely in deal practice: acquiring a Swiss operator of critical infrastructure means assuming its running reporting obligation on day one, including the personal fine exposure under Art. 74h ISG. This belongs in the due diligence checklist, in a dedicated rep and warranty, and in the disclosure schedule — not as a footnote but as a standalone item. Buyers who have not built this into SPA negotiations for critical-infrastructure targets are leaving a live obligation unaddressed.

Listed companies with fewer than 30 percent women on the board must explain reasons and measures in the remuneration report for the 2026 financial year under Art. 734f OR. The market average sits above the threshold, which provides no cover: the 30 percent test is applied company by company, not against a sector benchmark. The piece is short and specific — boards that have been tracking the aggregate Swiss figure and treating it as a safe harbour need to reread the provision before the 2026 remuneration report is drafted.

The Switzerland–EU package's dynamic alignment mechanism means that material Binnenmarkt changes reach Swiss law on a track where the Vernehmlassung is too late for any practical influence. Today's Trend Dispatch puts the practical consequence bluntly: monitoring EU legislative pipeline at the working-group and trilog stage is no longer optional for legal departments with significant EU-adjacent exposure. The Vernehmlassung signals adoption, not opportunity. The opportunity is the COM proposal stage, two to three years earlier. For teams that have been treating EU monitoring as an add-on to Swiss compliance work, Bilateral III makes it a standing function. Related reading: our May piece on dynamic adoption and the state-aid cantonal subsidy angle.