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Switzerland (CH) · Module Detail

Switzerland: Legal & Litigation

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.

Standing sub-brief · as of 27 June 2026174 words · last cycle 2026-06-27

Legal & Litigation

The Swiss competition authority COMCO investigated whether Apple Pay was interrupting the TWINT payment process on newer NFC terminals, concluding that TWINT's claims were correct and pursuing remedies including open access to TWINT at scheme, issuing and acquiring levels with no exclusivity — a significant market-structure ruling. Open, non-exclusive access reshapes mobile-payment competition and constrains Apple Pay NFC behaviour, a precedent relevant beyond Switzerland.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T3https://resources.fenergo.com/newsroom/global-financial-regulatory-penalties-fall-by-18-in-2025-as-enforcement-shifts-from-us-to-emea-and-apacretrieved
  2. T3https://washingtoncentre.org/us-aml-and-sanctions-enforcement-fines-fall-sharply-in-2025/retrieved
  3. T1https://one.oecd.org/document/DAF/COMP/WD(2025)41/en/pdfretrieved
  4. T1https://www.finma.ch/en/supervision/cross-sector-issues/combating-money-laundering/retrieved