The Ledger: NNSFlow blog

Insights from thecompliance engine room

Field notes, engineering deep-dives, and regulatory commentary from the team building NNSFlow for Swiss financial institutions.

Latest articles

Negative news screening for Swiss casinos: navigating AMLA and the Money Gaming Act
Industry

Negative news screening for Swiss casinos: navigating AMLA and the Money Gaming Act

Swiss casinos sit under two laws and a different supervisor than banks. The AML expectations are not lighter and the documentation bar is just as high. Here is what gaming-board audits actually check.

Antoine Bedaton
Antoine Bedaton
04 May 202611 min read
casinos
FinIA expectations for Swiss asset managers: AML obligations under FINMA supervision
Industry

FinIA expectations for Swiss asset managers: AML obligations under FINMA supervision

Since FinIA came into force, Swiss asset managers and trustees report directly to FINMA. The AML obligations did not get lighter, the audit bar got more explicit. Here is what FINMA actually checks.

Antoine Bedaton
Antoine Bedaton
29 Apr 202611 min read
finia
Transaction monitoring vs negative news screening: where they meet, where they don't
Industry

Transaction monitoring vs negative news screening: where they meet, where they don't

Transaction monitoring watches payment flows; negative news screening investigates entities. Buyers conflate them. Here is what each system actually does and where they hand off to each other.

Antoine Bedaton
Antoine Bedaton
16 Apr 202610 min read
monitoring
Managing false positives in AML screening: a Swiss-aligned disposition framework
Compliance

Managing false positives in AML screening: a Swiss-aligned disposition framework

Auditors do not measure how few alerts you generated. They measure whether each disposition is consistent, justified, and reproducible. Here is the disposition framework that survives a Swiss AML audit.

Antoine Bedaton
Antoine Bedaton
02 Apr 202611 min read
false-positives
Vendor due diligence: what a Swiss bank's procurement team should be asking
Industry

Vendor due diligence: what a Swiss bank's procurement team should be asking

A Swiss bank evaluating a software vendor is not running a generic procurement exercise. Specific FINMA circulars, the Banking Act's secrecy provisions, and SBA self-regulation set the floor for what has to be asked. Here is the version of the checklist that maps to the regulation.

Antoine Bedaton
Antoine Bedaton
18 Mar 202610 min read
procurement
Air-gapped deployment: what actually breaks
Engineering

Air-gapped deployment: what actually breaks

Most web apps that claim to run on-premise have not been tested with the network unplugged. The result is a long tail of things that silently fail, hang, or quietly phone home. Here is the audit checklist we run before every on-prem release.

Antoine Bedaton
Antoine Bedaton
05 Mar 202611 min read
on-premise

Product

New capabilities, workflows, and field stories from real screening operations.