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Dossiers

Deep analysis, worked through
and sourced

Where the Regulatory Watch tracks what is changing, dossiers work through what it means — longer analysis on the questions that do not fit on a card, each one sourced to the primary material.

August 2026Open

Explainer · beneficial ownership

Beneficial ownership: the person behind the structure

What beneficial ownership means, explained from zero, and how the three register systems this practice works across — EU, UK, Swiss — each answer 'which human being controls this entity?'. The shared 25% threshold and why each regime words it differently; who is allowed to look (the UK shows the public, the EU those with a legitimate interest, Switzerland only the authorities from 1 October 2026); and how an investigator walks an ownership chain through all three. With three check-yourself questions.

Beneficial ownershipAMLRRegulation 2024/1624PSC registerCompanies HouseTJPGFATFRegisters
August 2026Open

Regulatory analysis · EU, UK, Switzerland

Three travel rules

The EU, the UK and Switzerland each impose a crypto travel rule, and the three figures that look comparable — €1,000, £800, CHF 1,000 — govern three different questions. What each text actually requires, why the UK sum changed on 30 June 2026, why Switzerland turns out to be the most restrictive of the three on self-hosted wallets, and what FATF says about the gap between legislating the rule and supervising it.

Travel RuleTFRRegulation 2023/1113MLRs 2017AMLO-FINMAFATFSelf-hosted walletsCASPs
August 2026Open

Regulatory analysis · Switzerland

FinIA: one Act, five licences, two supervisors

The Financial Institutions Act has been in force since 1 January 2020: one statute licenses five categories of non-bank financial institution, splits their supervision between FINMA and a private layer of supervisory organisations, and rewired the Anti-Money Laundering Act through its Annex. Read for the architecture as it stands in the in-force text, six years of licensing practice in FINMA's own numbers (the 2020 wave of 1,921 applications, 1,664 licences, 109 pending), and the financial-crime pressure points — including the four-way SO consolidation confirmed by the merger FINMA approved on 11 December 2025.

FinIAFINIGSwitzerlandFINMASROsSupervisory organisationsAMLALicensing
August 2026Open

Regulatory analysis · Switzerland

The Swiss crypto licence

Switzerland proposed two new FinIA licence categories in October 2025 — payment institutions and crypto institutions — and repealed the fintech licence outright. The consultation closed on 6 February 2026 and nothing has been published since. Read from the German consultation package: what the draft does, the block-freeze-recall duty on stablecoin issuers, why neither licence can yet be priced, and the MiCA comparison that sits untranslated in the explanatory report.

SwitzerlandFINIGStablecoinsCryptoMiCAFINMA
August 2026Open

Regulatory analysis · Switzerland

Supervised by whom

FATF's standard says virtual asset service providers must be supervised by a competent authority and not a self-regulatory body. Switzerland supervises most of its crypto businesses through SROs, and is rated Largely Compliant. How that was reconciled in a single passage of a 2020 follow-up report, what actually differs between the two supervisory channels, and why a pending reclassification would settle the question without ever naming it.

FATFFINMASROsVASPsSupervisionSwitzerland
August 2026Open

Reference · European Union

MiCA's technical standards: the index that does not exist

MiCA's Level 2 and Level 3 measures arrive piecemeal across ESMA, the EBA and the Commission, and no consolidated public index of them exists. This one is derived from the Regulation itself and verified instrument-by-instrument on EUR-Lex: 50 empowerments — 26 regulatory technical standards, 10 implementing technical standards and 14 sets of guidelines — with every Commission adoption attributed by its legal-basis recital. All 10 ITS and 24 of 26 RTS are adopted; the two gaps sit exactly where the ART register is empty.

MiCATechnical standardsESMAEBAReference
August 2026Open

Training module · European Union · Part 2 of 2

MiCA: the application, phase by phase

An interactive walk through a CASP authorisation with a clearly-labelled composite applicant — eight phases from perimeter analysis to the first supervisory cycle, with the practitioner's task list and the decision-maker's brief side by side, the stakeholders each phase brings into the room including the regulator-side ones, and the AML workstream running alongside all of it. MiCA times only two things: 25 working days for completeness and 40 for assessment. Everything that decides the outcome happens before the clock starts.

MiCACASPAuthorisationAMLTraining
August 2026Open

Training module · European Union · Part 1 of 2

MiCA: building the permission set

An interactive module on MiCA authorisation. Select any combination of the ten crypto-asset services and the panel recomputes the prudential class and floor, the service-specific articles that attach, what each service does to the anti-money-laundering function, and — from the ESMA register itself — whether any firm in the EU has been authorised for that exact shape and by which authority. Ten services make 1,023 combinations; 86 are in actual use across 330 authorised firms.

MiCACASPAuthorisationAMLTraining
August 2026Open

Regulatory analysis · Switzerland

What a Swiss SRO affiliation is actually worth

A crypto business tells a counterparty abroad that it is regulated in Switzerland. The statement is almost always true, and it does not say which of the two Swiss supervisory channels it sits in — a public authority that can disgorge profits and ban executives, or a private association whose ultimate sanction is expulsion. The case that the badge is thin, the case that it is substantive, and where the argument actually lands: the phrase is not a statement about the firm but about a register entry, and nobody can test SRO supervision from outside because none of it is published.

FINMASROsDue diligenceSupervisionSwitzerland
August 2026Open

Regulatory analysis · Switzerland

Switzerland's crypto travel rule, and the proof it demands

Switzerland applies the travel rule to crypto more strictly than anywhere else: a supervised institution may release coins to an external wallet only once it has established who controls it, and where that wallet belongs to a third party it must run full customer due diligence on a person who is not its customer. The requirement sits in a three-page FINMA notice of 2019 that never defines what would count as proof. The six methods FINMA has since accepted, collected here for the first time, why one of them is a screenshot, and why the May 2026 revision of the ordinance left the requirement out.

FINMATravel ruleUnhosted walletsSupervisionSwitzerland
August 2026Open

Regulatory analysis · Swiss supervision

What FINMA cannot do

Switzerland's financial supervisor has no power to fine — a gap Credit Suisse turned from a design choice into a live question. What Arts 31–37 FINMASA actually permit, what the Federal Administrative Court did and did not decide in B-2334/2023, why the AT1 bonds are still worthless, and what the consultation open until 19 November 2026 would change.

FINMASupervisionEnforcementCredit SuisseSwitzerland
August 2026Open

Regulatory analysis · EU supervision

The account that is not an account

Almost a quarter of EU payment-institution supervisors told the EBA that virtual IBANs obscure who holds the account. Read against a crypto sector that grew 2.5-fold in two years and is converging on the same services: what the EBA's fifth and final Opinion found, where the restrictive-measures guidelines stand eight months into application, and why every AML citation naming the EBA as the responsible authority is now wrong on the institution.

AMLVirtual IBANsCASPsEBAAMLATravel rule
August 2026Open

Method · the MiCA perimeter

Finding the unauthorised

Since 1 July 2026 the perimeter question is binary and checkable: either an entity is in the ESMA register — as a specific legal entity, for specific services, in specific states — or it may not serve EU clients at all. The method: how to run the check, how to read the register of the non-compliant without over-reading it (evidence of what it records, never of what it omits), what ESMA's wind-down expectations require, and how narrow reverse solicitation really is. Names no entity on this practice's own judgment; every figure carries its snapshot date.

MiCACASPsAuthorisationRegistersReverse solicitationMethod
July 2026Open

Case studies · what the evidence delivered

Matters that turned on the evidence — and what running it early changes

Nineteen worked matters — fifteen public cases (Autonomy, Wirecard, P&ID, the Staley/Barclays ban, Parmalat, 1MDB, Glencore and more) and four clearly-labelled anonymised composites — across fraud, arbitration, conduct & employment and concealment, read for what the evidence delivered and what it would have delivered run earlier. For in-house teams, general counsel, and the firms that instruct us.

Case studiesFraudArbitrationEmploymentEvidence
July 2026Open

Concept · evidence handling

One matter, one channel

A design for where the evidence should live: one matter reference, one secure Swiss-hosted channel agreed at engagement, every arrival logged, one working copy, and source material returned or deleted on completion. How matters are set up in this practice — and why the filing decision is the cheapest one you'll ever make early.

EvidenceData protectionMethod
July 2026Open

Explainer · on-chain evidence

Reading the chain

How to read a transaction on a public block explorer — hashes, UTXOs and accounts, confirmations, gas, and where labels stop being evidence — and what the travel rule actually demands under FATF Recommendation 16, Regulation (EU) 2023/1113 and FINMA's stricter Swiss practice. For the practitioner who needs the ledger as citable evidence, not folklore.

BlockchainTravel ruleFATFEvidence
July 2026Open

Worked example · on-chain evidence

Tracing in practice

One transaction traced end-to-end at the practice's evidence standard — the 10,000 BTC pizza payment, cited so a stranger can re-derive it — then the Ronin bridge attribution handled with the layers separated, and a rotating set of real on-chain exercises (genesis block, DOJ seizure wallet, sanctioned addresses, token traps) with model answers. The companion piece to Reading the chain: the method, performed.

BlockchainEvidenceTrainingWorked example
July 2026Open

Hot topics · regulator priorities

What's live now — FCA, FINMA and the EU

A dated board of current regulator priorities across the FCA, FINMA and the EU (AMLA / ESMA / EBA): the crypto rulebook, the authorisation gateways, market abuse, the travel rule, operational resilience — what each is, when it bites, and why it matters, with a plain-language glossary. Kept current; re-verified quarterly.

RegulatoryCryptoAMLCurrent
July 2026Open

Explainer · the UK, from first principles

How UK AML supervision actually works

Who the regulators are, what each one's mandate is, who can fine — written for a reader starting from zero. The FATF's authority explained from first principles, the FCA/HMRC/professional-body supervision map, the SAR plumbing, and the coming rewiring: the FCA as single AML supervisor for professional services, with OPBAS wound up.

UKAMLSupervisionExplainer
July 2026Open

Analysis · UK–Swiss market access

The Berne corridor: market access by deference

The Berne Financial Services Agreement, in force since 1 January 2026, lets UK and Swiss firms serve each other's wholesale markets under home-state rules — regulator deference by treaty. How the mechanics work, how deference differs from equivalence and legislation, and how quickly the window can close.

UKSwitzerlandMarket accessTreaty
October 2025Open

Dossier · the Swiss AML system

Seven instruments carry the whole system

The seven statutory instruments of Swiss anti-money-laundering law — AMLA, AMLO-FINMA, CDB 20, the criminal-code articles (305bis/ter, 102), FINMASA, and the market-architecture layer — each with its key provisions, a practitioner note, and primary sources.

SwitzerlandAMLFINMARegulatory stack
October 2025Open

Opportunities · the same machinery, run early

Five engagements, seeded from the fraud register

Five recurring engagement patterns — tech-assisted investigation (Airbus), back-book rescreen (Swedbank), proof-of-reserves (FTX), counterparty-concentration review (Archegos), and a monitoring stress-test (NatWest) — each read against the precedent that made it necessary and what running it early would change.

EngagementsInvestigationsCase studies
October 2025Open

Analysis · cross-regime load

The Overlap: where the same function collides across regimes

Six financial-crime functions read against six instruments (Swiss AMLA, EU AMLA, AMLR, MiCA, DORA, ECCTA) — a collision matrix showing where EU, UK and Swiss obligations load the same function at once, seen from the regulator's, the in-house team's, and the firm's point of view.

Cross-borderAMLMiCADORA

Available on request

Earlier long-form reports, sent by email on request.