June 2025 Regulatory Updates

What Changed

• - Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election...
• Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
• Updates are published in the Federal Gazette and integrated into FINMA's continuously maintained sanctions lists for automated screening.

Suggested Considerations

• Immediate screening: Run updated Annex 2 against client databases, transactions, and assets; block and report any matches to FINMA via SR system.
• Enhanced due diligence: Review Guatemala exposures for links to designated parties (e.g., Public Prosecutor’s Office officials, FCT); suspend dealings and notify self-certification.
• System updates: Ensure sanctions screening tools (e.g., World-Check, Refinitiv) reflect changes; train staff and document compliance.
• Reporting: File suspicious activity reports (SARs) to MROS if pre-existing dealings detected; retain evidence of non-execution of prohibited transactions. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/

Key Dates

References

• [1] finintegrity.org/september-2025-sanctions-and-export-cont...
• [2] steptoe.com/en/news-publications/stepwise-risk-outlook/sa...
• [3] lupicinio.com/en/international-sanctions-%C2%B7-june-2025/
• [4] imf.org/-/media/files/publications/cr/2025/english/1gtmea...
• [5] alacosanctions.com/sanctions-guide-june-2025/
• [6] finma.ch/en/documentation/international-sanctions-and-com...
• [7] swlegal.com/en/insights/newsletter-detail/finma-risk-moni...
• [8] finma.ch/en/news/2025/10/20251027-fatf-statement/

What Changed

• This is an enforcement decision, not a regulatory change introducing new rules; it reinforces existing obligations under French financial markets law and MAR:
• Shareholder reporting thresholds: Mandatory notification to AMF and issuers for crossing above or below capital/voting rights thresholds, plus six-month plans.
• Prohibition on false/misleading information: Press releases denying control over entities when factual arrangements prove otherwise qualify as market manipulation.
• Inside information confidentiality: Issuers must prevent premature public access to sensitive releases, even unintentionally. No new requirements were enacted; the decision clarifies application to...

Suggested Considerations

• Shareholders: Implement automated threshold monitoring systems; file timely declarations (immediately upon crossing, with six-month plans) via AMF portal. Document all share transfers, including indirect control via trusts/companies.
• Issuers: Secure pre-publication access to financial releases (e.g., website password protection); conduct pre-release audits. Train IR teams on confidentiality protocols.
• All firms: Review governance for personal attribution risks; audit recent disclosures for misleading statements. Enhance MAR compliance training, focusing on complex ownership structures.
• Immediate: If involved in similar transactions (2016-2021 period referenced), self-assess and remediate reporting gaps.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] amf-france.org/en/news-publications/news-releases/enforce...
• [3] amf-france.org/en/news-publications/news-releases/enforce...
• [4] finascope.fr/english/reglementation/la-commission-des-san...
• [5] amf-france.org/en/news-publications/news-releases/enforce...
• [6] aosphere.com/know-how/cross-border-distribution-examples-...
• [7] solutions-atlantic.com/france-amf-fines-for-takeover-repo...
• [8] morganlewis.com/events/2026/01/regulatory-enforcement-and...