Regulatory

Effective 1 October 2026, the revised Swiss Anti-Money Laundering Act will extend Switzerland‘s anti-money laundering framework to advisers participating professionally in covered transactions. Lawyers, notaries, fiduciaries, accountants, tax advisers, M&A advisers and other professionals may become subject to due-diligence, organizational and certain reporting requirements under the AML framework even if they do not execute financial transactions themselves. This article summarizes the new regime, its principal exemptions and its consequences for professional advisers.

Effective as of 11 January 2027, CRD VI introduces an EU-wide restriction on third-country institutions‘ cross-border lending activities. Under the new article 21c CRD VI, Swiss banks may no longer extend loans, provide guarantees, or make credit commitments to EU-domiciled borrowers without an authorized subsidiary or branch in the relevant member state. The prohibition covers all corporate finance activities with an EU nexus, including syndicated credit facilities.

On 1 April 2026, the Federal Council introduced the draft Sustainable Corporate Governance Act as a counterproposal to the Responsible Business Initiative 2.0. The proposed legislation seeks to align Swiss law with the latest amendments to corporate sustainability regulations in the EU by instituting broadly framed sustainability due diligence obligations and enhanced sustainability reporting requirements for large to very large Swiss companies. In addition, the draft outlines the creation of a special liability framework and introduces supervisory mechanisms to ensure compliance.

On 1 July 2025, FINMA Circular 2025/4 on consolidated supervision entered into force. This codification of FINMA‘s longstanding supervisory practice for financial groups in line with international standards enhances regulatory clarity. One year after its entry into force, it makes sense to assess the Circular‘s practical impact and the extent to which consolidated supervision has featured in FINMA‘s recent practice. As this issue will likely remain relevant in the coming years, this contribution examines FINMA‘s expectations as set out in the Circular and as applied in practice.

The Swiss Parliament has approved the Investment Screening Act (ISA) which forms the basis of the Swiss FDI regime, on 19 December 2025. As no popular referendum had been initiated by the end of the respective deadline on 17 April 2026, the ISA will enter into force and the Federal Government is expected to publish the implementing ordinance later this year. The purpose of the ISA is to prevent the acquisition of Swiss undertakings by foreign state “controlled” investors if this would threaten the public order or security in Switzerland. Acquisitions of Swiss companies operating in particularly critical sectors by…

On 22 October 2025, the Swiss Federal Council initiated the consultation process for a revision of the Financial Institutions Act. The proposed legislation aims to increase financial innovation under the Swiss regulatory framework. Under the revised Financial Institutions Act, the Federal Council, intends to introduce a new license category, the “Payment Instrument Institution“ which will replace the current FinTech license (also referred to as the banking license light) provided for under article 1b of the Federal Act on Banks and Savings Institutions. In the context of the consultation process on the Federal Council‘s draft legislation, the new licensing category has…

Until 6 February 2026, the Swiss Federal Council consulted on the introduction of a comprehensive regulatory framework for payment instrument institutions through amendments to the Financial Institutions Act. The proposed legislation, published for consultation on 22 October 2025, aims to establish Switzerland as a leading hub for stablecoin issuance while addressing perceived critical gaps in customer protection and financial stability. This contribution examines the key features of the new regulatory regime, with particular emphasis on the controversial exclusion of banks from issuing Swiss Stablecoins and the implications for Switzerland’s financial sector.

In October 2025, the Swiss Federal Council proposed two new licensing regimes – a payment institution and a crypto institution license – intended to replace the fintech license, which has not lived up to expectations. This article, focusing on the crypto institution license, assesses whether the new framework has the potential to reinvigorate Switzerland‘s fintech and crypto sector. In particular, it examines the proposed regulatory requirements for crypto institutions, which closely mirror those applied to securities firms, in relation to the business models and risk profiles of such institutions as well as the regulatory regimes of peer jurisdictions. The analysis…