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B-04-29 FINMA Guidance 05/2021

Preventing and Combating Greenwashing

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Money laundering

Adoption of the revision of the anti-money laundering measures

On September 26, 2025, the Federal Chambers adopted the latest revision of the anti-money laundering measures, which began in the summer of 2023. For the record, the government's bill had two parts. The first related to the introduction of an electronic register of beneficial owners of companies, through a new law on the transparency of legal entities and the identification of beneficial owners (LTPM). The second consisted of several amendments to the AMLA, the most controversial of which was the[...]

Money laundering

MROS negative typologies : a welcome tool or a false good idea ?

The MROS publishes ‘negative typologies’. The aim is to raise awareness among financial intermediaries (FIs) of the substance of the clarifications and to improve the quality of data to enable it to be processed efficiently, which is to be welcomed. It is not certain that this objective will be achieved, as some typologies leave practitioners perplexed. Here are a few thoughts from a practical perspective on some of the typologies published on 16 September 2025. Typology 2: In the absence[...]

1MDB case

Confirmation of a ban on practicing

In its ruling 2C_368/2023 of August 6, 2025, handed down by five judges but not intended for publication, the Federal Supreme Court upheld the ban on practicing imposed on the former member of the management of Banca della Svizzera Italiana SA (“BSI”) more than two years after confirming that imposed on the former Head of Legal & Compliance (decision 2C_747/2021, commented on in: Braidi, cdbf.ch/1286). The appellant, former CEO of BSI Singapore Ltd. and member of the management of BSI,[...]

Explainability of an AI system

Clarifications from the Financial Stability Institute

On 8 September 2025, the Financial Stability Institute (FSI) published a document aimed at clarifying what is meant by ‘explainability of artificial intelligence systems’ and certain options for how to meet this requirement. This document is particularly important given that FINMA has made explainability one of the key points for banks to consider in its Communication 08/2024 of 18 December 2024 on the supervision of governance and risk management in relation to the use of artificial intelligence (see Caballero Cuevas,[...]

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