On 14 July, SECO revised the annex to the ISIL (Da'esh)/Al-Qaida sanctions ordinance for the second time since April — and, as with the March 2025 move to the standalone SR 946.231.08 regime, names bind the moment SECO publishes, no EU cross-check required. We wrote about the mechanics of that UN 1267 track in May: if your screening tool is only keyed to the EU consolidated list, this is exactly the update it will not catch.

The WBF has revised Annex 8 to the ordinance of 4 March 2022 on measures against Russia — the same instrument behind the 20th sanctions package Bern adopted on 22 May. If a counterparty's status shifted under this annex, check whether it touches any material-adverse-change clause currently on your desk; we laid out who carries the burden of proof when a sanctions package is the textbook trigger event.

On 5 June the WBF amended Annex 2 to the Sudan ordinance of 25 May 2005 (SR 946.231.18) — the same annex we tracked in February, when the Swiss update lagged the corresponding EU listing by twenty days. Worth checking whether the lag held this time; if your screening cadence assumes same-day parity with Brussels, it shouldn't.

The WBF also amended the annex to the ordinance of 10 April 2024 on 17 June — FINMA's own newsflash gives the ordinance date and the SR number and stops there, no regime named. That is the actual compliance burden hiding in these notices: the alert tells you something changed, not what. Budget the five minutes on Fedlex before closing the ticket.

Further back in the queue: SECO updated the Taliban sanctions list on 1 May, and the WBF amended Annexes 12 and 14 of the Iran ordinance of 12 December 2025 on 14 April. Both are routine — the Iran ordinance itself was the bigger story when it replaced the JCPOA-era regime outright — but if your screening log shows a gap on either date, close it now, not at the next audit.

Swiss prosecutors are opening more foreign-bribery cases, and the coverage still frames it as an enforcement gap. It isn't — Art. 102 Abs. 2 StGB criminalizes the company for failing to organize against bribery, not the underlying act, and a rising case count is what a statute working as designed should produce. If there is a gap, it's inside the compliance program.

Same beat as the item above, and the same instinct worth correcting: there is no gift-value threshold under Art. 322septies StGB — what matters is whether the gift connects to an official act, not what it cost. A cheap gift tied to a pending decision is worse exposure than an expensive one with no official act in sight. A gift policy that still runs on a CHF figure is answering the wrong question.

The comparison is more useful than the headline lets on. What made Brexit politically radioactive was less the exit than what followed it — rules bound to a court the departing country no longer sat on. Bilaterale III does the same thing in reverse: Swiss market-access agreements now track ongoing EU legislation and EuGH interpretation, and legal departments are already living that binding today, ratification vote or not.

The framing question answers itself once you read the parliamentary file: the Investitionsprüfgesetz was sold as light-touch, but what emerged from committee is a real gating step for inbound M&A. Put the screening question in the term sheet, not in a closing condition you discover in week six.

A useful pairing with the item above: one story is Switzerland tightening the door on capital coming in, the other is Switzerland unable to open the door on capital going out. A freeze under the Embargo Act immobilizes assets; it does not transfer title — Art. 26 BV still stands between Bern and any confiscation, however many billions the headline totals.

The commercial framing — AI vendors selling into border control — sits directly on top of the legal one mapped in May: the KI-VO's Annex III high-risk obligations for biometric systems were provisionally pushed to 2027, which means the vendors have a longer runway to sell than they have to comply. A Swiss provider in that market should not read the delay as a green light.

Pairs naturally with the item above: both are about how much surveillance capacity the law lets the state build before proportionality has to answer for it. The BVGer's ruling in A-5373/2020 held that providers of derived communication services don't automatically inherit the retention duties of full telecom carriers — five years after the underlying dispute started, still the operative line for anyone deciding what a VÜPF request actually reaches.