Casimir von Firn's piece today maps what changed on 11 June: the Commission's confirmed authority to access personal mobile phones during inspections. The immediate task is not rewriting the dawn-raid protocol — it is auditing whether your BYOD and personal-use policies were ever drafted on the assumption the Commission wouldn't ask. Most were. The legal analysis is in today's article; the action item is a conversation with IT governance before the next Q3 inspection round.

Servatius von Tatzenberg today shows how the partial revision of the Produktesicherheitsgesetz uses the Vernehmlassung process to transplant the EU General Product Safety Regulation framework into Swiss law — not with a headline announcement, but through a consultation that opened 5 June and closes 28 September 2026. The deadline is three months out, not imminent, but the text is live now. If you manufacture or import consumer goods for the Swiss market, today's article is the one to read before end of day.

Casimir von Firn today answers the M&A drafting question that has been live since the Foreign Subsidies Regulation entered full enforcement: the FSR filing belongs as a condition precedent, not a pre-closing covenant. The logic is simple — the Commission has blocking power, and a closing risk you cannot cure is a closing condition. Where it gets harder is the MAC clause. We mapped the MAC/change-in-law problem in May; the FSR prohibition is a specific variant that the drafting needs to address separately. Does a Commission block constitute a MAC or a failed condition? The answer affects who bears the break fee. Get that resolved at term sheet, not at signing.

Servatius von Tatzenberg today tracks the CJEU reference asking whether FATCA and AIA bulk transmissions are proportionate under the Charter of Fundamental Rights. The referral — lodged December 2025, accepted February 2026 — signals the court takes the question seriously. A ruling that bulk automatic exchange fails proportionality would not directly void the bilateral FATCA treaty, but the CJEU could void the EU's implementing acts requiring transmission, forcing non-implementation — the same mechanism that unravelled Privacy Shield in Schrems I and II. Banks in multiple jurisdictions would face that operational exposure simultaneously. Read alongside our May piece on Art. 47 BankG and the only legal channel for foreign data requests: the FATCA transmission sits in a different regime, but the gap between treaty obligation and data protection law is the same fault line. The next enforcement crisis will emerge from exactly that gap.

The WBF updated Annex 2 of the Sudan ordinance on 5 June — the fourth amendment this year, following updates in February (twice) and April. If your last full-portfolio screen predates that amendment, run it again. Our May analysis of the Sudan list's timing lag versus EU listing remains current: the gap between Brussels listing and Swiss ordinance amendment means your EU-regulated counterparties may have screened and acted before the Swiss update was live. That asymmetry is your exposure window.

The partial revision of the FINMA Anti-Money Laundering Ordinance closed for comment last Monday. FINMA now analyses responses; expect the final text in Q4 2026 with a transition period. We flagged in May why "no new obligations" in the FINMA press release was not the whole story: the three key clauses — Art. 9b on ownership and control structure documentation, Art. 65 Abs. 2 Bst. d on sub-account beneficial owner declarations, and Art. 30/37 on sanctions screening and correspondent-banking transitory account restrictions — tighten what is already required without creating new categories. Institutions that waited for the final text before beginning implementation are now behind the curve by at least a quarter.

Swissinfo's piece on AI at European borders corrects a talking point circulating since the AI Act omnibus (adopted November 2025): the 2027 deadline extension defers conformity assessment obligations for Annex III standalone high-risk systems to 2 December 2027 — not governance. Governance obligations under the GPAI framework applied from 2 August 2025 and were not deferred. Border biometric applications — facial recognition at entry/exit, automated risk-scoring, traveller identification — are Annex III high-risk systems under Art. 6 of the AI Act whether the deadline moved or not. We mapped this distinction in May. Suppliers who have not yet begun conformity assessment work are not in violation today, but December 2027 is a firm compliance deadline — not a registration-only date. Swiss suppliers of biometric infrastructure to Frontex or national border agencies should have conformity assessment under way now.

Hunton Andrews Kurth becomes the latest major US firm to close its China office. The pace has accelerated through 2025–2026, and the parallel contraction in Hong Kong compounds the problem. For Swiss companies with China operations, regulatory complexity in that jurisdiction — data localisation, export controls, cross-border data transfer restrictions — has never been higher, while senior international coverage is shrinking. The question for in-house is whether you have built enough internal capability or local-firm relationships to absorb that gap before you actually need them.

The transparency register under the TJPG goes live mid-2026 — which is now. The most persistent misconception worth addressing one more time: the Handelsregister already captures beneficial owners. It does not. It shows directors and shareholders above the disclosure threshold, which is not the same as the GwG-defined wirtschaftlich Berechtigter. The TJPG filing goes to a separate register with a separate definition and a separate enforcement regime. Two registers, two definitions, one company to get it right. Our May piece explains the practical workflow implications, including where the two frameworks diverge on beneficial ownership chains through trusts.

Today's FSR article and our May piece on the Investitionsprüfgesetz describe the same transaction from two angles: a non-EU-state-backed acquirer buying Swiss critical infrastructure. Both regulatory regimes can fire simultaneously. The FSR notification requires two cumulative conditions: at least one party with EU aggregate turnover ≥ €500m, and aggregate financial contributions from third countries exceeding €50m across all parties combined over the preceding three years. The ISG captures acquisitions of Swiss critical infrastructure by foreign investors. Different thresholds, different competent authorities, different filing deadlines relative to signing, and no settled market practice yet on which condition precedent is drafted as the primary closing risk. This is the conversation that needs to happen between M&A counsel and regulatory counsel at term sheet stage. On most Swiss deals it still happens at signing, which is too late.

SECO updated the Taliban list (SR 946.231.07) in May; the FINMA notification formalises it. Screening teams running Taliban on a quarterly cycle rather than on each amendment carry an exposure that an examiner will find. The Taliban list runs on two parallel tracks — the Swiss domestic ordinance and the underlying UN 1267 list — and they do not always update in synchrony. Our May analysis of the UN 1267 architecture explains why that dual-track structure requires your screening system to be configured for both, not just the Swiss ordinance.

Swissinfo's piece on the March 8 climate fund initiative defeat resurfaces a point worth repeating: a domestic vote against climate legislation does not move the CSDDD deadline by a day. Swiss exporters with EU customers are already within scope of the Corporate Sustainability Due Diligence Directive's value chain emissions disclosure obligations — through their contracts, not through Swiss federal law. We wrote in May about how CSDDD binds Swiss exporters contractually before the domestic NUFG framework enters force. The ballot result is irrelevant to that exposure.