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Revision of the anti-money laundering provisions

Publication of the draft and dispatch by the the Federal Council

On 22 May 2024, the Federal Council published the bill revising the anti-money laundering provisions. The revision comprises two parts. The first follows on from the amendment of FATF Recommendation 24 on the transparency of legal persons in early 2022. It provides for the introduction of a federal register of beneficial owners of companies, by means of a new law on the transparency of legal persons and the identification of beneficial owners (P-LTPM). The second part consists of several amendments[...]

Cyber attacks

New reporting obligation takes shape

From 1 January 2025, banks, insurance companies and financial market infrastructures will have to report cyber attacks to the Federal Office for Cyber Security (FOCS) within 24 hours. The Federal Council has just put out to consultation the draft ordinance that implements art. 74a ff of the Federal Act on Information Security (obligation to report cyber attacks). As we explained earlier (see Hirsch,, banks will now have to inform the OFCS in the event of a cyber attack. The[...]

Rules of conduct under FinSA

FINMA launches consultation on new circular

FINMA has published a draft of a new circular entitled "Rules of Conduct under the Investment Services Financing Act and the Investment Services Financing Ordinance". The aim of the draft is to enhance legal certainty two years after the end of the transitional period following the entry into force of these standards and the first prudential audit cycle on this subject. Overall, it is a relatively modest project. Rather than extending the scope or providing a general commentary, it is[...]

transparency in non-financial matters

Is the legal nature of the AGM vote a false debate ?

This year, the general meetings of public-interest companies meeting the criteria of Art. 964a para. 1 of the Swiss Code of Obligations will be asked to approve their reports on non-financial matters in accordance with Art. 964c para. 1 of the Swiss Code of Obligations. In this context, a controversy has arisen over the legal nature of the vote: on the one hand, Novartis and Roche have already organised a consultative vote, while on the other, the Ethos Foundation is[...]

The L-QIF is coming!

The revised CISA and CISO come into force on 1 March 2024

At its meeting on 31 January 2024, the Federal Council adopted the amendments to the CISO and decided that the amendments to the CISA relating to the limited qualified investor fund (L-QIF), adopted on 17 December 2021, would enter into force. As a reminder, the L-QIF is a collective investment reserved for qualified investors within the meaning of the CISA that is not subject to approval or authorisation by FINMA (art. 118a CISA). It may take the form of a[...]