Who We Serve
We defend corporations, executives and financial institutions facing Swiss criminal investigations, FINMA enforcement proceedings and cross-border regulatory actions.
Banks & Financial
Institutions
Banks, private banks, asset managers, insurance companies, and SRO-regulated financial intermediaries facing FINMA enforcement proceedings, criminal investigations, or cross-border regulatory actions.
Executives & Board
Members
C-suite executives, board members, compliance officers, and external asset managers facing personal criminal liability, industry bans, allegations of criminal mismanagement or exposure to corporate criminal liability proceedings.
FinTech & Crypto
Firms
FinTech companies, crypto exchanges, token issuers, and virtual asset service providers (VASPs) facing FINMA investigations, unauthorised activity proceedings, or criminal complaints related to digital asset operations.
What We Do
From pre-investigation risk assessments to courtroom defence before the Swiss Federal Criminal Court.
Internal Investigations
Privilege-protected internal investigations designed to identify regulatoryPrivilege-protected internal investigations designed to identify regulatory breaches and mitigate criminal exposure. breaches and mitigate criminal exposure.
Criminal Defence
Representation in proceedings for fraud, embezzlement, criminal mismanagement, forgery, and money laundering.
FINMA Enforcement Defence
Defence against FINMA enforcement proceedings, including industry bans, disgorgement of profits, and licence revocation proceedings.
Mutual Legal Assistance
Defence against incoming MLA requests, challenging evidence transfers to foreign authorities before the Federal Office of Justice and the Federal Criminal Court.
Sanctions & Embargo Compliance
Advisory on Swiss (EmbA), EU, and OFAC sanctions regimes. Frozen-asset management, SECO licensing requirements, and sanctions-screening programme design for financial intermediaries.
Cross-Border Coordination
Multi-jurisdictional defence strategy for cases involving DOJ, SEC, SFO, FCA, or EU authorities. Coordination with local counsel while managing the Swiss component including compliance with Art. 271 of the Swiss Criminal Code (prohibited acts for a foreign state).
Why Switzerland
Switzerland's position as the world's largest cross-border wealth centre places it at the intersection of global enforcement trends.
Intensified FINMA Enforcement
Following the Credit Suisse crisis, FINMA has significantly hardened its enforcement posture. FINMA supervises banks, insurers, and financial intermediaries with expanded tools including industry bans, disgorgement orders, and publication of enforcement decisions. Proposed reforms would grant FINMA the power to impose direct monetary fines — a fundamental shift in Swiss supervisory culture.
Expanding International Cooperation
Switzerland processes approximately 1,500 mutual legal assistance requests annually. The Federal Office of Justice coordinates with over 60 treaty partners. Since adopting the Automatic Exchange of Information (AEOI) in 2017, Switzerland shares financial account data with over 100 jurisdictions, making banking secrecy largely ineffective as a defence strategy.
Corporate Criminal Liability
Under Art. 102 of the Swiss Criminal Code, corporations face direct criminal liability when offences cannot be attributed to a specific individual due to inadequate internal organisation. For specified offences such as money laundering and bribery, corporate liability arises even when the individual perpetrator is identified.
Strong Procedural Rights for the Accused
Swiss criminal procedure provides robust defence rights: mandatory access to case files, strict rules on pre-trial detention, and the ability to challenge seizure orders within 10 days. Attorney-client privilege is constitutionally protected and carries criminal sanctions for breach. Ensuring effective defence is possible even in complex proceedings.
Why Allegra LAW
What sets us apart in Swiss white-collar defence and regulatory investigations.
Conflict-Free Defence
Allegra LAW does not act as institutional counsel to major banks. This allows us to avoid structural conflicts of interest common in large full-service firms.
Rapid Response Capability
Dawn raids, asset freezes, and arrest warrants demand immediate action. Allegra LAW maintains rapid-response capability and can mobilise immediately when required.
Absolute Discretion
All communications are protected by Swiss attorney-client privilege in accordance with applicable law.
Former Regulatory Professionals
Allegra LAW's team includes professionals with direct FINMA experience, bringing first-hand supervisory experience and insight into enforcement priorities and regulatory expectations.
Cross-Border Network
Allegra LAW coordinates with trusted counsel in all major jurisdictions — US (DOJ/SEC), UK (SFO/FCA), EU authorities — for seamless multi-jurisdictional defence while managing the Swiss component.
Investigation Expertise
Allegra LAW structures internal investigations to be privilege-protected, regulator-defensible, and operationally efficient — identifying exposure before it escalates to formal enforcement action.
What We Cover
A comprehensive overview of our white-collar crime and investigations practice.
Criminal Offences
✓ Fraud & embezzlement
✓ Money laundering
✓ Bribery & corruption
✓ Document forgery
✓ Criminal mismanagement
Investigations & Enforcement
✓ FINMA enforcement proceedings
✓ Internal investigations & forensics
✓ Corporate criminal liability
✓ Mutual legal assistance
✓ Sanctions & embargo violations
Defence & Compliance
✓ Pre-trial defence strategy
✓ Asset freezing & seizure challenges
✓ Plea negotiations
✓ Whistleblower response
✓ Compliance programme design &
remediation
Frequently Asked Questions
Key questions about white-collar defence and investigations in Switzerland.
What triggers a FINMA enforcement proceeding?
FINMA may initiate enforcement proceedings under FINMASA Arts. 30–37 when it identifies a serious violation of supervisory law. Common triggers include suspicious activity reports (SARs) forwarded by MROS, whistleblower disclosures, audit findings from FINMA-appointed auditors, or information received through international supervisory cooperation. Allegra LAW's team includes professionals with direct FINMA enforcement experience, allowing us to anticipate regulatory priorities and structure early interventions that can prevent proceedings from escalating.
Can a corporation face criminal charges in Switzerland?
Yes. Under Art. 102 of the Swiss Criminal Code (StGB), a corporation can be fined up to CHF 5 million if an offence cannot be attributed to a specific individual due to deficient internal organisation (para. 1). For specified offences — including money laundering (Art. 305bis), bribery (Art. 322ter et seq.), and terrorism financing (Art. 260quinquies) — corporate liability exists even when the individual perpetrator is identified (para. 2). Allegra LAW advises corporations on compliance framework design that meets Art. 102 organisational requirements, and defends corporate clients when charges are brought.
Can foreign authorities compel Swiss banks to disclose client data?
Not directly. Foreign authorities must submit a formal mutual legal assistance request under IMAC (SR 351.1) or the applicable bilateral treaty. Switzerland's Federal Office of Justice evaluates each request for compliance with treaty requirements, dual criminality, and proportionality. Affected clients have the right to challenge data transfers before the Federal Criminal Court in Bellinzona. Allegra LAW regularly defends clients against incoming MLA requests, challenging overbroad evidence demands and ensuring that Swiss procedural protections are fully enforced.
How quickly must we respond to a dawn raid or asset freeze?
Immediately. Under StPO Art. 263, seized assets and documents can be challenged within 10 days. However, the first 24–48 hours are critical for preserving rights, instructing employees on their obligations under Art. 113 StPO, and ensuring attorney-client privilege is properly asserted over protected materials per Art. 264 StPO. Allegra LAW maintains rapid-response capability and deploys within hours of first contact — because the earliest moments of an investigation often determine its outcome.
What role does MROS play in Swiss AML enforcement?
The Money Laundering Reporting Office Switzerland (MROS) receives and analyses suspicious activity reports from financial intermediaries under AMLA Art. 9. If MROS identifies sufficient grounds, it forwards the report to the competent prosecution authority. MROS can also freeze assets for up to five working days under Art. 23 AMLA. In recent years, MROS has received over 12,000 SARs annually — a record volume reflecting increased compliance awareness. Allegra LAW advises financial intermediaries on MROS reporting obligations and represents clients who become subjects of MROS-initiated investigations.