Cross-border investigation & regulatory intelligence
Know where it stands.
Decide with fewer unforced errors.
An independent investigations and regulatory practice in Luzern, working across the UK, the EU and Switzerland — for the desk, for senior managers and decision-makers in fintech and traditional finance, and for the counsel who advise them. Everything here is current, cited and dated, so it can be checked, rebutted and relied on; the practice turns difficult matters into fixed-fee written work you can act on.
The first conversation is free.
Jurisdictions we work across.
At the desk
Every claim on this site carries its source and its date: check it, cite it, rebut in real time at every level of pushback.
In the boardroom
Fewer unforced errors: know what binds today, what is still moving, and which doors are still open, before you commit.
Built because coming back is hard. Information that is slow, stale or unverifiable is how unforced errors happen — so this is one place, with less noise: geographic Europe, not just the EU; current, referenceable, built for 2027 and beyond. Read the story →
Methodology
From evidence to work product
A single, coherent workflow: send us the evidence, and we organise and analyse records, communications, and regulatory filings into clear work product — handled compliantly from intake to return.
Evidence Received
Evidence arrives through a secure channel agreed for the matter — financial records, correspondence, corporate filings, regulatory submissions — from any branch, business, or border, organised under one matter reference.
Analysis
Entity mapping, cross-referencing, and anomaly detection with the best available tools.
Pattern Recognition
Identification of concealed relationships, recurring transactional patterns, and structural indicators of fraudulent schemes.
Timeline Construction
Automated chronological mapping of events, actors, and transactions spanning years or decades of corporate activity.
Work Product Returned
Structured reports, risk assessments, and research memoranda returned to you. Source material is returned or deleted on completion — only the work product is retained.
Jurisdictional Coverage
Three Jurisdictions. One Integrated View.
Comprehensive regulatory intelligence across the European Union, the United Kingdom, and Switzerland — with direct links to principal enforcement and supervisory authorities.
European Union
EU Regulatory Framework
United Kingdom
UK Regulatory Framework
Switzerland
Swiss Regulatory Framework
Regulatory Watch
See what's coming, and what it means
A living view of the instruments changing cross-border financial-crime and digital-asset work — how far along each is, who it affects, and where to go for the detail. For a firm with EU, Swiss and UK exposure, the same rule can mean three slightly different things.
Swiss AMLA revision + Transparency Register
Revised Anti-Money Laundering Act & Transparency Act (LETA)
Enters into force: 1 Oct 2026
Switzerland's revised AMLA and the new Federal Act on the Transparency of Legal Entities create a central, non-public register of beneficial owners administered by the Federal Office of Justice, and extend due-diligence duties to certain advisory activities.
For the in-house compliance officer
Redesign onboarding and beneficial-ownership verification, build register-reporting workflows, and assess whether advisory work now falls within scope. Transition periods begin on the in-force date; newly incorporated entities must register within one month.
A Swiss measure, but groups with EU/UK arms must reconcile it with EU beneficial-ownership registers and the UK PSC regime — similar intent, different mechanics and access rules.
Source: Federal Council / SIF →EU AMLA — the new supervisor
EU Authority for Anti-Money Laundering (AMLA)
Direct supervision begins: 1 Jan 2028
The EU's new central AML supervisor, operational in Frankfurt since 1 July 2025, with direct supervision beginning in 2028 under Regulation (EU) 2024/1620. Eligibility is gated: AMLA periodically assesses credit and financial institutions and groups only where they operate "in at least six Member States, including the home Member State" — and expressly "regardless of whether the activities are carried out through infrastructure on the territory concerned or remotely", so passporting in without local establishment counts. From those, it selects on risk profile up to 40 groups and entities "at least during the first selection process"; where more than 40 qualify, the tie-break is breadth — those operating in the highest number of Member States. The cohort is reviewed on a three-year cycle. Crypto-asset service providers are named in the supervised population, and AMLA also coordinates supervisors of the non-financial sector, including self-regulatory bodies.
For the in-house compliance officer
Two questions, and they are different. Will AMLA supervise you? Start with the gate, not the risk: fewer than six Member States and you are outside direct supervision altogether, however high your risk profile — and remote, passported activity counts toward the six. Above the gate, selection runs on risk, with breadth as the tie-break where more than 40 qualify. The live timetable: national supervisors collected data to 15 August 2026, a provisional list of eligible entities is expected by end-September 2026, selection follows in 2027. And what happens if you are selected? AMLA may impose pecuniary sanctions capped at 10% of total annual turnover for the most serious breaches (or €10m for others), adjusted by the coefficients in Annex I, with any benefit derived or third-party loss added on top of that cap — plus periodic penalty payments of up to 3% of average daily turnover to compel compliance. Model both now: eligibility is being assessed this quarter, not in 2027.
The design differs sharply from the other two regimes, before any question of how it is used. The FCA fines without a statutory ceiling (FSMA s.206); AMLA fines against a turnover-proportionate cap with a published coefficient methodology; FINMA cannot fine at all and reaches the money by confiscating profit instead, with criminal fines sitting elsewhere entirely. A group operating across all three cannot carry one mental model of "supervisory penalty". Note also that AMLA’s remit reaches self-regulatory bodies — the model Switzerland runs at its core.
Source: AMLA (europa.eu) →MiCA — crypto-asset framework
Markets in Crypto-Assets Regulation (MiCA)
Transition window closed: 1 Jul 2026
The EU's comprehensive regime for crypto-asset service providers and token issuers. The last national transitional regimes closed on 1 July 2026: a provider without MiCA authorisation may no longer serve EU clients, and reverse solicitation is the only — narrow, closely-scrutinised — residual route.
For the in-house compliance officer
The cliff has passed. Verify your own and your counterparties' authorisation against the ESMA register; wind down any EU book still running on a lapsed national regime; document why any remaining EU-client contact is genuine reverse solicitation. Expect early enforcement to target exactly these two gaps.
An EU passport regime: CH-based providers reach EU clients only via an EU-authorised entity; UK firms face a separate domestic perimeter.
Source: ESMA →UK crypto regime — FSMA authorisation
UK cryptoasset regime — full FSMA authorisation
Crypto activities fully within FSMA: 25 Oct 2027
The FCA's final cryptoasset regime (published 30 June 2026) brings crypto activities fully within FSMA. AML-only registration ends: every UK-facing crypto firm needs full authorisation. A joint FCA–Bank of England approach covers systemic stablecoin issuers.
For the in-house compliance officer
The application window opens 30 September 2026. Current MLR-only registrants must prepare a full authorisation application — governance, prudential and conduct standards, not just AML controls.
A separate perimeter from MiCA: authorisation in one bloc gives no rights in the other. Firms serving both markets run two applications and two rulebooks.
Source: FCA →Berne Agreement — UK–Swiss mutual recognition
Berne Financial Services Agreement (UK–Switzerland)
In force: 1 Jan 2026
A UK–Swiss treaty recognising each other's regulation as delivering equivalent outcomes across five wholesale sectors, including banking and investment services. Firms serve the other market under their home rules and home supervisor — regulator deference by treaty.
For the in-house compliance officer
Check eligibility first: the corridor covers wholesale and sophisticated clients only, sector by sector. Map which services ride on the Agreement, follow the notification routes, and hold a contingency plan — the treaty has its own suspension and termination machinery.
The direct London–Zurich rail. FINMA and the FCA/Bank of England operate it through cooperation arrangements; it is treaty-based and mutual, unlike unilateral EU equivalence decisions.
Source: GOV.UK — treaty text →Practice Areas
Specialist Domains
We take cases that run across years and jurisdictions, where the evidence is too large to review by hand.
Complex Fraud
Multi-jurisdictional fraud schemes spanning years or decades, involving layered corporate structures and concealed beneficial ownership.
Money Laundering
Tracing illicit financial flows through placement, layering, and integration across banking systems and corporate vehicles.
Market Manipulation
Identification of spoofing, layering, wash trading, and insider dealing patterns across trading venues and dark pools.
Bribery & Corruption
Cross-border corruption investigations under the UK Bribery Act, FCPA, and equivalent EU and Swiss provisions.
Sanctions Evasion
Detection of sanctions circumvention through shell companies, front entities, and obfuscated payment channels.
Cartel Investigations
Analysis of price-fixing, market allocation, and bid-rigging conduct across European competition law regimes.
What we do
Areas we work in
Three areas where we take on work. Each engagement begins with a conversation — and, where the matter calls for it, an in-person assessment — so the scope, the people, and the approach are set around the matter in front of you. Nothing here is off-the-shelf.
Independent internal investigations
Before a matter is handed to a law firm — or as part of the mandate to one — we investigate it properly: evidence gathered from every branch and entity, local or international, through a channel agreed for the matter, organised and analysed, with the work product returned to you. Sometimes that recipient is a government department.
Where investigations meet employment law
Conduct, directors' responsibility, and the right to work in a regulated function often collide. In the UK, a financial institution may need to refer an investigation to the regulator before an individual can take up another financial role. Done properly, it serves the regulator, the former employer, and the employee alike — and an independent specialist can often do it with more focus, and at a more proportionate cost, than a general law firm.
The European regulatory transition
Two shifts, one programme. MiCA is widely discussed; the AMLA framework now entering into force far less so. We help firms move into both without duplicating effort, and reconcile Swiss and EU obligations from a single, coherent operating picture.
Every engagement begins with a discussion. If one of these speaks to a problem you are facing, the most useful next step is to book a conversation — the first one is free.
Book a discussionThe whole site
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Work with the practice
Intelligence
Learning
- The MiCA courseMiCA from scratch in nine sections — no prior knowledge assumed.
- SanctionsHow five regimes are built, with a walkthrough and worked cases.
- SupervisionHow supervisors think, taught from their own published work.
- Blockchain & Travel RuleRead a public blockchain and apply the Travel Rule.
- ToolsGuided walks: the entity checker and the token sort.
- TrainingAll the practice's free courses and the curated resource library.
- GlossaryThe site's terms, each defined and sourced.
- SavedYour bookmarks and course progress — stored on this device only.
- ResourcesCurated official databases and tools for the work itself.