title: Switzerland — Legal & Litigation | World Payments Monitor canonical: https://payments.gi/jurisdictions/switzerland/w7/ publisher: Asymmetric Intelligence ### W7 Legal & Litigation Confirmed confirmed 2026-06-27 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 2026 174 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. 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)** 1. T3 [https://resources.fenergo.com/newsroom/global-financial-regulatory-penalties-fall-by-18-in-2025-as-enforcement-shifts-from-us-to-emea-and-apac](https://resources.fenergo.com/newsroom/global-financial-regulatory-penalties-fall-by-18-in-2025-as-enforcement-shifts-from-us-to-emea-and-apac) retrieved 2026-06-27 2. T3 [https://washingtoncentre.org/us-aml-and-sanctions-enforcement-fines-fall-sharply-in-2025/](https://washingtoncentre.org/us-aml-and-sanctions-enforcement-fines-fall-sharply-in-2025/) retrieved 2026-06-27 3. T1 [https://one.oecd.org/document/DAF/COMP/WD(2025)41/en/pdf](https://one.oecd.org/document/DAF/COMP/WD(2025)41/en/pdf) retrieved 2026-06-27 4. T1 [https://www.finma.ch/en/supervision/cross-sector-issues/combating-money-laundering/](https://www.finma.ch/en/supervision/cross-sector-issues/combating-money-laundering/) retrieved 2026-06-27