Skip to main content


The fight against money laundering

Commentary on the MROS Annual Report 2023

The MROS Annual Report 2023 has been published discreetly. Only certain points are commented on. The statistics include 11,876 communications corresponding to 21,500 business relationships (+56%, a tenfold increase in 10 years), 90.5% of which came from banks, while asset managers, lawyers, notaries and trustees remain largely under-represented. Fraud remains the leading predicate offence (see this analysis). 14.5% of reports concerned crypto-currencies, the importance of which is probably underestimated (see this specific report, commented on in Tharin, No surge[...]

Too big to fail

A senior managers regime gaining ground in Switzerland

In its report of 10 April 2024 on bank stability, the Federal Council proposes the development of a senior managers' regime (SMR) as part of the "Too Big To Fail" (TBTF) framework. An SMR assigns specific responsibilities to the most senior managers and makes it easier for the supervisory authorities to identify those at fault. This commentary focuses on one of the 37 measures analysed by the Federal Council in its report (for a general commentary on the report, see[...]

Money laundering using digital assets

Adaptation of the financial industry despite growing use and increasing risks

On 28 February 2024, the Federal Office of Police's Interdepartmental Coordination Group on Combating Money Laundering and the Financing of Terrorism (Fedpol) presented its second report on the money laundering risks associated with digital assets (i.e. digital assets based on blockchain technology such as Bitcoin or Ethereum). The report is of interest to financial intermediaries active in this area - in particular compliance functions - and proposes various recommendations to improve the fight against money laundering. It also highlights certain[...]