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Insights 02.08.2025

The EU AI Act: Update on the application timeline and implications for Swiss companies

The EU AI Act: Update on the application timeline and implications for…

Regulation (EU) 2024/1689 of 13 June 2024 laying down harmonised rules on Artificial Intelligence (“AI Act”) marked a significant milestone in the European Union's regulation of AI technologies. Due to its extraterritorial application, also companies based in Switzerland and other non-EU-countries may potentially be subject to the AI Act. The AI Act formally entered into force one year ago, but its substantive rules are applied in a phased approach. Effective 2 August 2025, a significant number of provisions under the AI Act came into force, while the final set of its provisions will only enter into force on 2 August 2026 and 2 August 2027, respectively.

Insights 29.07.2025

OFAC sanctions enforcement against Interactive Brokers: Important compliance lessons (also) for Swiss financial institutions

OFAC sanctions enforcement against Interactive Brokers: Important…

On 15 July 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced a settlement with Interactive Brokers LLC ("IB"), a U.S.-based global brokerage firm. The case, which resulted in a penalty of nearly USD 12 million, arose from compliance deficiencies related to sanctions screening, client location controls and oversight of introducing brokers. Although the enforcement action concerns U.S. regulations, it offers highly relevant lessons for Swiss financial institutions. In particular, the case illustrates how U.S. authorities evaluate the effectiveness of sanctions compliance frameworks in digital and cross-border contexts. OFAC's findings underscore the importance of integrating technical access controls (e.g., IP filtering), robust screening and escalation procedures, as well as careful oversight of third-party introducers.

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