On July 31, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) amended the annex to the Syria Asset Freezing Ordinance (SR 196.127.27), originally enacted March 7, 2025, to update the list of designated individuals subject to comprehensive asset freezes. This amendment reflects Switzerland's ongoing implementation of targeted financial sanctions against politically exposed persons connected to the former Assad regime, requiring immediate compliance from all financial intermediaries and asset holders operating in Swiss jurisdiction.
What Changed
The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices.
The amendment operates under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA; SR 196.1), which provides the legal...
Suggested Considerations
*Immediate compliance steps for financial institutions:
*Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
*Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
*File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
*Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities
Key Dates
March 7, 2025, 6:00 PM UTC
– Original Syria Asset Freezing Ordinance entered into force
July 31, 2025, 6:00 PM UTC
– Amendment to annex (list of designated persons) entered into force
Ongoing
– Immediate freezing obligation upon designation; no grace period applies
Four
year validity; – The ordinance remains valid for four years from March 7, 2025, unless extended or modified
Warning Savings protection Warning Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Warning Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Informs insurers of the issuance of the Consultation Paper on Proposed Changes to the Group Capital Framework for Designated Financial Holding Companies (Licensed Insurer).
AI Analysis
The Monetary Authority of Singapore (MAS) issued a consultation paper on 24 July 2025 proposing amendments to Notice FHC-N133, which governs the valuation and capital framework for Designated Financial Holding Companies (Licensed Insurer) under the enhanced risk-based capital (RBC 2) consolidation approach. These changes aim to refine the group capital framework by incorporating global regulatory updates and market developments, ensuring more robust capital treatment for non-insurance entities, joint ventures, and non-controlling interests. Compliance professionals should prioritize this as it directly impacts capital adequacy calculations for affected groups, with the consultation now closed post-25 August 2025.
What Changed
The proposals target refinements to the group capital framework in Notice FHC-N133 (effective 1 January 2024) and include:
Risk charging approach for non-insurance entities (NIEs): Introduce a standardized method to assess and charge capital for risks posed by NIEs within the DFHC group, with potential additional charges...
Enhanced capital treatment for joint ventures (JVs): Strengthen requirements to better reflect JV risks in group capital computations.
Limit on recognition of capital from non-controlling interests (NCIs): Cap the amount of NCI capital recognized in group financial resources to account for its non-fungible nature (currently, NCI...
Suggested Considerations
Gap analysis: Model impacts on group financial resources, identify data/ system gaps for NIE/JV risk assessments, and simulate capital shortfalls under new limits.
Stakeholder engagement: If not already done, firms that submitted feedback by 25 August 2025 should track MAS response; prepare internal policy updates and board reporting on potential capital adjustments.
Ongoing: Enhance monitoring of non-insurance subsidiaries and JVs; update valuation processes to align with RBC 2 consolidation once finalized.
Key Dates
1 January 2024
- Effective date of baseline Notice FHC-N133 (pre-amendment)
24 July 2025
- Issuance of Consultation Paper P011-2025 on Proposed Changes to the Group Capital Framework
25 August 2025
- Consultation closing date (now passed as of February 2026)
Compliance Impact
Urgency: Medium - The consultation closed on 25 August 2025, reducing immediate pressure, but as of February 2026, no final rules or effective dates are confirmed, creating uncertainty for 2026 capital planning. This matters for DFHCs as changes could increase capital requirements, affect dividend capacity, and necessitate system recalibrations, with non-compliance risking supervisory actions under RBC 2; proactive modeling is essential to avoid last-minute adjustments.
Informs insurers of the issuance of the Consultation Paper and Quantitative Impact Study on the Proposed General Insurance Catastrophe Risk Requirement
AI Analysis
The Monetary Authority of Singapore (MAS) issued a consultation paper on 24 July 2025 proposing a new **General Insurance Catastrophe Risk Requirement (GI Cat risk charge)** under the enhanced Risk-Based Capital 2 (RBC 2) framework to capture extreme events not covered by existing premium and claim liability risks. This matters for general insurers as it introduces standardized scenarios for Singapore Insurance Fund (SIF) and Offshore Insurance Fund (OIF), plus bespoke scenarios, potentially increasing capital requirements and necessitating model governance and quantitative impact studies (QIS). Compliance professionals must engage promptly as the consultation closed on 5 September 2025, with implementation likely following RBC 2 enhancements.
What Changed
- Introduction of GI Cat risk charge: Captures natural (e.g., standardized flood for SIF; whole-of-portfolio for OIF) and man-made catastrophe risks (e.g., fire/explosion, economic events, pandemic)...
SIF computation: Prescribed standardized scenarios (flood for natural; fire/explosion, economic event, pandemic for man-made) plus annual "Own Bespoke" scenario for material risks like earthquakes or...
OIF computation: Standardized man-made scenarios plus annual "Own Bespoke" for man-made risks; natural cat on whole-of-portfolio basis using vendor/in-house models with governance requirements;...
Aggregation approach: Specified method for combining GI Cat risk charges across funds.
Accompanying QIS to assess impacts, building on prior studies (2021 preliminary, 2022 stress test, 2024 survey).
Suggested Considerations
Complete and submit QIS for SIF and OIF general business (exemptions apply for certain reinsurers' OIF).
Provide feedback on consultation questions, including standardized scenarios, "Own Bespoke" requirements, OIF materiality threshold, flood parameters, and governance for models.
Review and prepare internal catastrophe models (vendor/proprietary) meeting proposed governance standards for OIF natural cat risks.
Assess capital impacts under proposed charges and aggregation; update RBC 2 compliance programs accordingly.
Monitor MAS website for final rules post-5 September 2025 (https://www.mas.gov.sg/regulation/circulars/id08_25).
Key Dates
24 July 2025
- Issuance of Consultation Paper (P012-2025) and QIS by MAS
05 September 2025
- Consultation closing date for feedback on proposals and QIS completion
08 December 2025
- Last revision date of related Notice 133 on Valuation and Capital Framework
Compliance Impact
Urgency: High - As of February 2026, consultation is closed, signaling imminent finalization and integration into RBC 2 (last revised Notice 133 on 8 December 2025), requiring proactive capital modeling, scenario testing, and governance updates to avoid supervisory scrutiny. Failure to prepare could elevate capital costs, disrupt RBC compliance, and expose firms to RBC 2 enforcement risks amid MAS's focus on insurer resilience.
Sanctions & settlements professional obligations Disclosure Obligations Other professionals Journalists The AMF Enforcement Committee fines a Danish investment bank for breaches of professional obligations committed by a French branch
AI Analysis
The AMF Enforcement Committee imposed a €300,000 fine on Saxo Bank A/S on 16 July 2025 for multiple breaches of professional obligations committed through its French branch, including failures to properly inform clients about significant changes to derivatives procedures, margin calculations, and securities transaction incidents, as well as deficiencies in equity savings plan (PEA) transfers. This enforcement action demonstrates the AMF's active oversight of cross-border investment banks operating in France and highlights critical gaps in client disclosure practices that compliance teams must address.
What Changed
The enforcement decision does not introduce new regulatory requirements but rather clarifies existing obligations under current French financial regulations.
Client notification requirements for significant procedural changes affecting derivatives trading and margin calculations
Incident disclosure obligations for securities transactions that could materially affect order execution
Timely information provision regarding regulatory consequences of the UK's withdrawal from the European Union as they affect PEA accounts
Operational procedures for managing equity savings plan transfers with proper documentation and client communication
Suggested Considerations
*Audit client notification procedures for derivatives trading changes, particularly regarding position closure procedures and margin calculation methodologies, ensuring clients receive advance notice of material changes
*Implement incident reporting protocols for securities transactions that could affect order execution, with documented evidence of timely client notification
*Review PEA transfer procedures to ensure compliance with regulatory timeframes and proper documentation of information provided to clients regarding Brexit-related consequences
*Strengthen information governance to ensure all material operational changes are communicated to clients within required timeframes and with appropriate detail
*Conduct compliance training for front-office and operations staff on professional obligations regarding client communication and information disclosure
Key Dates
16 July 2025
- AMF Enforcement Committee decision issued imposing €300,000 fine
22 July 2025
- Official publication of enforcement decision
No specified deadlineDEADLINE
- Appeal period available (no specific timeframe stated in the decision)
MAR Financial disclosures & corporate financing Shares The AMF and the AFA call for vigilance of the risk of private corruption by criminal networks of natural persons with access to inside information
Sanctions & settlements MAR professional obligations Investment advice Other professionals Journalists Listed companies and issuers The AMF Enforcement Committee fines eight individuals and two legal entities a total of €1,890,000 for late...
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
AI Analysis
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring models.
Suggested Considerations
Monitor developments: Track ACPR/AMF Fintech Forum updates for potential voluntary certification pilots or EU harmonization under MiCA/pending DeFi rules.
Review internal practices: Align smart contract governance, audits, and change management with endorsed principles (e.g., third-party audits, risk-based recertification on material changes).
Enhance documentation: Prepare for possible protocol-level certification, including modular DeFi interactions and continuous on-chain monitoring.
Engage stakeholders: Participate in future consultations via industry groups like GDF or Adan to influence voluntary frameworks.
Key Dates
2024
- Working Group conducts analysis and drafts report on smart contract certification
3 February 2025
- Report published for public consultation
14 March 2025
- Industry responses submitted (e.g., GDF, Adan)
16 July 2025
- Summary of consultation responses published by ACPR and AMF
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Thomas Hirschi has decided to leave the Swiss Financial Market Supervisory Authority FINMA effective 31 August 2025. The Head of the Banks division will pursue a new career outside FINMA. FINMA’s Board of Directors and Executive Board thank Thomas Hirschi for his valuable contribution during his time at FINMA.
Supervision Governance Sustainable Finance Journalists Investment management companies The AMF publishes a summary of its SPOT inspections on asset management companies' voting and engagement policies
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
AI Analysis
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Haiti (SR 946.231.139.4), dated December 16, 2022, aligning Switzerland's sanctions regime with recent UN Security Council decisions. This matters for Swiss financial institutions as it mandates immediate screening against potentially updated lists of designated persons and entities, reinforcing asset freezes, travel bans, and an expanded arms embargo to address Haiti's instability. Non-compliance risks FINMA enforcement actions under anti-money laundering and sanctions frameworks.
What Changed
- Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in...
Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing travel bans, asset freezes, and arms...
Swiss Implementation: FINMA oversees enforcement via SECO's sanction ordinances; updates require alignment with UN lists for asset freezing and prohibitions on dealings with designated parties.
Suggested Considerations
Screen Immediately: Check client databases, accounts, and transactions against the updated SECO/UN Haiti Sanctions List for new designations; freeze assets/economic resources without prior notice.
Cease Prohibited Activities: Halt dealings (direct/indirect) with designated parties, including financial services, brokering, technical assistance, or transfers related to military goods/technology.
Report Findings: Notify SECO/FINMA of matches or frozen assets, providing additional compliance details; maintain records for audits.
Update Policies/Systems: Revise sanctions screening tools, train staff, and monitor for "connected persons" under updated definitions.
License Checks: Apply for exemptions only if explicitly available (e.g., humanitarian); no dealings without approval.
Key Dates
October 17/20, 2025
UNSC Committee adds 2 entries to Sanctions List; Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response
October 18, 2024
UNSC Resolution 2752 adoption; Expands arms embargo scope, basis for national implementations
Immediate/publication date (2025/07/09 per FINMA notice)
Swiss Annex amendment effective; No grace period specified; aligns with "without delay" freezing requirements
July 23, 2025
UK Haiti Sanctions Amendment effective; Parallel indicator of timeline for UN-aligned changes
October 21, 2025
Swiss WBF/VTG announcement; Confirms amended sanctioned list
Compliance Impact
Urgency: High – Immediate asset freeze obligations apply "without delay" upon list updates, with FINMA's enforcement type indicating potential fines or reputational damage for lapses; matters due to Haiti's volatility driving frequent UN changes, risking secondary sanctions exposure for Swiss firms with international ties.
Long term investment Equity Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers French retail investor stock market activity: the AMF analyses changes in behaviour between...
MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body
Risk and Trend Mapping Markets Fixed income Asset management Other professionals Executive & other private individuals Fintech The AMF publishes its 2025 Markets and Risk Outlook
On 3 July 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultations on the new Ordinances on the Risk Diversification of Banks and Securities Firms and on the Liquidity of Banks and Securities Firms. The consultations will go on until 29 September 2025.