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FINMA can impose enforcement measures and sanctions for AMLA breaches; under the SBA's CDB 20 code of conduct an offending bank can be fined up to CHF 10m. Recent landmark exposure includes a USD 985m (EUR 835m) penalty issued to a Swiss bank by French authorities in 2025 — the single largest global AML penalty of the year — and Credit Suisse's USD 511m US penalty resolving undeclared-account/money-laundering probes. Domestically, competition authority COMCO investigated the TWINT/Apple Pay NFC-suppression dispute, ultimately securing open access to TWINT at scheme/issuing/acquiring levels with no exclusivity, a significant market-structure ruling.
On enforcement, the single largest AML penalty of 2025, USD 985m (EUR 835m), was issued to a Swiss bank by French authorities over AML failings, making France the second-largest enforcer globally. Separately, Credit Suisse's USD 511m US penalty dominated 2025 banking enforcement, resolving undeclared-Swiss-account and money-laundering probes for US clients. These are carried here as W7 litigation/enforcement, not original illicit-finance analysis; their AML significance overlaps the FIM surface and is routed via cross-monitor flags.
Outlook
The COMCO open-access remedy is the key precedent to track for cross-border read-across; large cross-border AML penalties signal continuing enforcement exposure for Swiss institutions, with the originating illicit-finance analysis sitting in FIM.
no periodic updates on record for this sub-brief
Sources and findings (4)
- T3https://resources.fenergo.com/newsroom/global-financial-regulatory-penalties-fall-by-18-in-2025-as-enforcement-shifts-from-us-to-emea-and-apacretrieved
- T3https://washingtoncentre.org/us-aml-and-sanctions-enforcement-fines-fall-sharply-in-2025/retrieved
- T1https://one.oecd.org/document/DAF/COMP/WD(2025)41/en/pdfretrieved
- T1https://www.finma.ch/en/supervision/cross-sector-issues/combating-money-laundering/retrieved