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
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 (TJPG/LETA)
In force: 1 Oct 2026
In force since 1 October 2026. The revised Anti-Money Laundering Act (AS 2026 322) brings "advisers" within the Act: those who professionally assist with real-estate purchases and sales, with forming, managing and administering non-operating legal entities, and who provide a domicile or seat for legal entities. Some provisions, including those for notaries in public employment, start later. The Transparency Act (TJPG, AS 2026 323) and its ordinance (AS 2026 364) launched a central, non-public register of beneficial owners run by the Federal Office of Justice, with filing through EasyGov. From the same date, reports to MROS must use goAML CH 2.0.2 (fedpol ordinance, AS 2026 440).
For the in-house compliance officer
Existing entities must file within one month of their first commercial-register change, and at the latest within three to six months depending on legal form and audit status — two years where every beneficial owner already appears in the commercial register; foreign legal entities have six months. Financial intermediaries' duty to report register discrepancies starts six months after commencement. Advisers newly in scope need due-diligence and organisational arrangements in place now, and suspicious-activity reporting must already run on goAML CH 2.0.2.
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 a sharper access contrast: the Swiss register is open to authorities and obliged entities only, not the public.
Source: Fedlex — AS 2026 322 (revised AMLA) →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 was expected by end-September 2026 but had not been published as at 2 October 2026; the first selection must start by 1 July 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 opened on 30 September 2026 and closes on 28 February 2027; the final perimeter guidance (PS26/18) was published on 16 September 2026. MLR registrations do not convert: firms that apply within the window may keep operating while their application is decided. The application is a full authorisation — 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 — gateway opens, 30 Sep 2026 →UK SPSS reform — FCA takes over AML supervision
UK AML supervision reform — FCA as single professional-services supervisor
First firms move to the FCA (government timetable): End 2028
HM Treasury decided in October 2025 that the FCA will become the single AML/CTF supervisor for legal and accountancy service providers and trust and company service providers — around 60,000 firms, moving from 22 professional body supervisors to one. Individual practitioners are expressly in scope, barristers included. The June 2026 response settled the powers: the FCA will rely on the existing Part 9 MLR toolkit rather than bespoke ones — financial penalties, public censure, prohibitions on senior managers or removal of authorisation, and criminal proceedings in serious cases. OPBAS ceases to exist once the transfer completes; until then OPBAS continues and the professional bodies keep their responsibilities. Treasury states implementation "will inevitably take several years". In the House of Lords on 7 September 2026, during the Financial Services and Markets Bill's Report stage, the government gave a timetable: the first FCA-supervised firms before the end of 2028, and all in-scope firms by mid-2030.
For the in-house compliance officer
The change is the supervisor's enforcement scale and publication habit, not the underlying obligations — the MLRs stay the MLRs. A professional body fines in the hundreds and thousands; the FCA publishes a Final Notice setting out findings of fact, and fines on a different order. Firms carrying AML weaknesses today are carrying them toward a regulator that documents them in public. Note what the SRA's own current enforcement already shows about the population being handed over: 935 proactive engagements in the latest period against 545 before, 833 firms inspected or desk-reviewed, and a third of firms non-compliant with 54% only partially compliant.
Moves the UK toward a concentrated supervision model as the EU centralises under AMLA — while Switzerland keeps SRO delegation. Three models, drifting further apart. The UK's is the only one of the three that moves an entire profession from self-regulation to a financial-services regulator.
Source: HM Treasury — decision (Oct 2025) and powers response (Jun 2026) →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.
Bribery & Corruption
Cross-border corruption investigations under the UK Bribery Act, FCPA, and equivalent EU and Swiss provisions.
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.
Civil fraud, asset recovery and tracing
Following money and assets across borders, and building the evidence to a standard that survives the application it is made for. The English courts have discharged worldwide freezing orders over how the underlying investigation was conducted; the gathering and the remedy are one problem, not two.
More on this →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.
More on this →Professional negligence
When a professional's own file becomes the evidence — advisers, auditors, solicitors, barristers and trustees. Reconstructing what was known, what was recorded and what a competent file would have contained, against the regulator's or tribunal's published findings rather than against hindsight.
More on this →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.
More on this →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
Everything here is one click deep
Work with the practice
Practice areas
- Civil fraudAsset recovery and tracing, and the evidence that has to survive a freezing application.
- EmploymentWhere an internal investigation has to satisfy a tribunal and a regulator at once.
- Fractional complianceAuthorisation files, AML programmes and the regulator's questions, run for the days the work needs.
- Professional negligenceWhen the professional's own file is the evidence — advisers, auditors, solicitors, trustees.
- Sports regulation & disputesGoverning-body disputes: discipline, appeals and arbitration under a sport's own rules.
Intelligence
Learning
- CryptoEverything here that is crypto-specific: MiCA, the Travel Rule, virtual-asset supervision and the two guided tools.
- GlossaryThe site's terms, each defined and sourced.
- ResourcesOther people's databases — the official registers, search tools and archives the work runs on.
- SanctionsHow sanctions operate, what each measure catches, and how five regimes are built.
- SportHow football's governing bodies make, enforce and review their rules, and where the courts come in.
- TrainingThe practice's own courses, free and open, with the reading behind each.