Russia's Annex 8 got another amendment this week, but it's one of five: Taliban, Sudan, ISIL/Al-Qaida and Iran have all moved since spring. None of these are the headline sanctions packages — they're the annex changes, and we've written before about exactly this problem: Sudan's list ran twenty days behind Brussels last time, and the ISIL list runs on its own UN track that country-based screening tools miss entirely. If your screening vendor updates on a monthly cadence, you have already had at least one gap this quarter.

Consultation ran to 9 June; FINMA called it "no new obligations" going in, which is precisely the framing we flagged as worth reading twice. Three clauses move the burden of proof on beneficial-ownership disclosure, whatever the press release says about scope. No final text yet. That's normal — but it means the working assumption in your compliance file should still be the draft, not the announcement.

The regulator praising a dispatch it lobbied for is not news. What's worth your five minutes is what's missing: four instruments FINMA asked for and didn't get — and separately, the capital, accountability and supervisory package that did make the cut. Third attempt at TBTF reform since 2008. Third time reading the annex matters more than the cover page.

We wrote about this in May: MBaer beat the FINMA licence withdrawal on procedural grounds, and it didn't matter, because FinCEN had already named the bank a primary money-laundering concern under its own authority, no coordination required. Liquidation proceeded regardless of the Swiss appeal outcome. If your Swiss entity has US correspondent banking exposure, the domestic appeal process is not the whole game anymore — it's not even the deciding move.

Girard took over the Banks division on 1 April, arriving from four years running Recovery & Resolution — the desk that plans for banks failing, not the desk that keeps them compliant day to day. Read that against the MBaer file above: a resolution specialist now sits over routine supervision at the same moment FINMA is publicly short the enforcement tools it wants from the Banking Act revision. That's not a coincidence worth a headline, but it's worth noting in the same paragraph.

Supervisory notice 02/2026 surveyed banks on digital fraud exposure and found gaps everyone in the room already knew about. FINMA is placing this under Art. 12 BankV operational risk management, not the money-laundering ordinance — which matters because fraud is a predicate offence to money laundering under Art. 146 StGB anyway. Your fraud KPIs need to reach the compliance board regardless of which article number they're filed under.

Swissinfo is recirculating the win, but the underlying ruling is the one we covered in May: BVGer A-5373/2020 held that providers of derivative communication services don't automatically inherit VÜPF's full surveillance obligations. Five years to get a proportionality line that holds. If you provide anything adjacent to encrypted communications in Switzerland, that ruling — not the headline — is what your outside counsel should be citing.

The marketing line has been "light touch" since the bill was introduced. The parliamentary record tells a different story — real conditionality that belongs in your term sheet, not an afterthought. If you're closing an inbound deal that touches infrastructure or critical technology, the screening clock starts earlier than the press coverage suggests.

More cases is a good headline and an incomplete one. Art. 102 para. 2 StGB puts the liability on companies without an organised compliance defence — the gap swissinfo is reporting is downstream of that: firms without a documented programme are the ones still getting caught out.

Same swissinfo roundup as the bribery-gaps item above, and it's the right companion question. Art. 322septies StGB has no gift threshold — the question is whether the gift connects to an official act, not what it retails for. A cheap gift tied to a pending decision is worse than an expensive one with no strings. Gift policies that set a franc ceiling are answering the wrong question.

The commentary keeps reaching for Brexit as the comparison, which misses the actual mechanism. Bilaterale III binds the internal-market agreements to ongoing EU legislation and ECJ interpretation — and that duty is already live, not something that starts when the package is ratified. Pair it with the state-aid control provisions reaching into cantonal subsidy decisions. Legal teams treating this as a future-tense problem are already behind.

One firm closing a China office is a business decision. This is a pattern, and it tracks the same direction as the export-control and CSDDD tightening we've been covering on the corporate side — Swiss exporters are already contractually bound by CSDDD ahead of the domestic NUFG legislation. If your outside counsel bench has been thinning in Asia, budget for the gap before the next cross-border deal needs it filled.