mercredi 15 juillet 2026
Dr. iur. Servatius von Tatzenberg
Six sanctions annexes have moved since March, and this week's FINMA batch caught up on the whole run at once — the loudest one, Russia, was still the least interesting.
SECO's Sudan annex gets a rewrite — still trailing Brussels
FINMA News (de)
The WBF touched the Sudan sanctions ordinance again — the same Anhang 2 of SR 946.231.18 whose February revision we flagged for landing twenty days after Brussels. The pattern holds: Bern updates on its own clock, and a screening tool keyed only to the EU consolidated list will miss this gap the same way it did last time.
Al-Kaida/ISIL list moves again — still on the UN track, not the EU one
FINMA News (de)
SECO updated the ISIL/Al-Kaida list under SR 946.231.08 — the ordinance we described as running on the UN 1267 track since March 2025. Names bind in Bern the moment New York's Sanctions Committee lists them; there is no EU intermediary step to watch for, which means an EU-list-only screening feed will never catch this one at all.
Iran ordinance gets another annex update — the cadence since December holds
FINMA News (de)
Anhänge 12 and 14 of the Iran measures ordinance were amended again — the latest in a steady run of annex updates since the 12 December 2025 total revision we wrote up as replacing the JCPOA-era framework. This is at least the fourth annex touch since then, after updates in late December, February and late February/early March. The new architecture is clearly getting maintained; whether your screening feed is keeping pace with it is the harder question.
Anhang 8 of the Russia ordinance changes — the list everyone already screens
FINMA News (de)
The WBF amended Anhang 8 of SR 946.231.176.72. Unlike Sudan or Iran, this one gets watched by every compliance vendor in the market — but "watched" and "current" are not the same claim, and each amendment is a fresh occasion to confirm the vendor actually ingested the update rather than just the entries that made headlines.
The Hamas/PIJ sanctions ordinance nobody screens for got updated too
FINMA News (de)
SR 946.231.09 — measures against persons and organisations supporting Hamas and Palestinian Islamic Jihad, in force since 10 April 2024 — had its annex amended again. It rarely makes anyone's shortlist of "the regimes we screen against," which sits alongside Russia and Iran on every deck. A compliance program built around the loud regimes has a blind spot shaped exactly like this one.
Prédiction: This ordinance surfaces in an enforcement file before it surfaces in a training deck.
Taliban list updated — the sixth sanctions annex change since March
FINMA News (de)
SECO amended the list under SR 946.231.07. Nothing dramatic on its own, but tally the run since March: Sudan, ISIL, Iran, Russia, Hamas/PIJ, now Taliban. "Sanctions screening" is not one list to reconcile against — it is at least six independently maintained ones, each on its own update cadence, and a single missed feed breaks the whole exercise quietly.
FINMA formally opens the AMLO-FINMA consultation — deadline still 9 June
FINMA News (en)
The consultation we covered from the draft side — "no new obligations," FINMA said, and three clauses that shift the burden of proof anyway — is now formally live as of 12 May. The deadline has not moved. If your compliance team hasn't drafted a response yet, there is less runway left than the "no new obligations" framing suggests.
Prédiction: Expect the response trickle to arrive in the final week before 9 June — don't be the trickle.
Swiss NGOs push to add cobalt to the responsible-business rules
SWI swissinfo.ch (en)
Campaigners want cobalt added to the mineral scope of Swiss responsible-business legislation. Worth reading next to the point we made about the CSDDD already binding Swiss exporters contractually, ahead of any NUFG vote: the domestic fight over which minerals count in Bern is somewhat beside the point for exporters whose EU customers already require CSDDD-equivalent diligence covering cobalt regardless of what gets enacted here.
Why pro-business Switzerland is warming to investment screening
SWI swissinfo.ch (en)
A useful primer on the politics behind a law we called "light touch" in name only. The parliamentary debate produced a real gatekeeping mechanism, and it belongs in the term sheet, not the closing memo.
Proton's surveillance-law win, years on, is still the citation everyone reaches for
SWI swissinfo.ch (en)
Nothing new here beyond a recap, but a reminder that the BVGer line we wrote up as holding for five years is still the reference point every derived-communication-service provider cites first. No sign of Bern trying to legislate around it yet.
Later today: what Commission v Malta does to your onboarding file once a residency claim starts reading like a red flag — for now, go check which sanctions feeds your vendor actually pulled this week.
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