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Cross-border investigation & regulatory intelligence

Complex evidence in.
Clear work product out.

Probative is an investigations and regulatory practice based in Luzern, Switzerland, working across the UK, EU and Switzerland. We take complex, multi-source evidence — from any branch, business, or border — organise it with the best available tools, and return clear, decision-ready work product. The aim is simple: to make a difficult matter easier for the person who has to deal with it.

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Jurisdictions we work across.

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.

I

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.

II

Analysis

Entity mapping, cross-referencing, and anomaly detection with the best available tools.

III

Pattern Recognition

Identification of concealed relationships, recurring transactional patterns, and structural indicators of fraudulent schemes.

IV

Timeline Construction

Automated chronological mapping of events, actors, and transactions spanning years or decades of corporate activity.

V

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.

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.

CH
Major

Swiss AMLA revision + Transparency Register

Revised Anti-Money Laundering Act & Transparency Act (LETA)

Adopted

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
Major

EU AMLA — the new supervisor

EU Authority for Anti-Money Laundering (AMLA)

In force

Direct supervision begins: 1 Jan 2028

The EU's new central AML supervisor, operational in Frankfurt since 1 July 2025. It will directly supervise around 40 selected high-risk obliged entities and coordinate national supervisors across the Union.

For the in-house compliance officer

Even before direct supervision in 2028, expect convergence: harmonised expectations, the selection process from mid-2027, and binding technical standards. Firms with EU exposure should map whether they could fall within the directly-supervised cohort.

Directly relevant to EU-established entities; for CH and UK firms it sets the supervisory tone counterparties and EU subsidiaries will be held to.

Source: AMLA (europa.eu)
EU
Major

MiCA — crypto-asset framework

Markets in Crypto-Assets Regulation (MiCA)

In force

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

Practice Areas

Specialist Domains

We take cases that run across years and jurisdictions, where the evidence is too large to review by hand.

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Complex Fraud

Multi-jurisdictional fraud schemes spanning years or decades, involving layered corporate structures and concealed beneficial ownership.

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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

Four 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.

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