Insights

Ahead of Switzerland’s next FATF mutual evaluation in mid-2027, the legislature and FINMA are tightening anti-money laundering requirements through a series of regulatory reforms taking effect in the second half of 2026, in particular through amendments to the Anti-Money Laundering Act (AMLA), the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA) and the introduction of a transparency register for legal entities (hereinafter “TJPG”). Below, we provide an overview of the three key developments and their practical implications for asset managers.

The revised Swiss Anti-Money Laundering Act (AMLA) and the new Transparency Register (TJPG), effective from 1 October 2026, introduce significant compliance obligations for banks, asset managers, collective asset managers and other financial intermediaries. Institutions must prepare for new transparency register requirements, assess whether existing advisory services fall within the scope of the AMLA, and adapt governance, KYC, onboarding and AML processes accordingly. Early analysis and implementation are essential to ensure regulatory compliance and operational readiness.

In view of Switzerland’s next FATF country review in mid-2027, legislators and FINMA are tightening regulatory requirements in the area of anti-money laundering in the second half of 2026, in particular through amendments to the Anti-Money Laundering Act (AMLA), FINMA’s Anti-Money Laundering Ordinance (AMLO-FINMA) and the introduction of a transparency register for legal entities. Furthermore, in Guidance 04/2026, FINMA has clarified its expectations regarding AML risk analysis. Below, we provide an overview of the key developments and their practical implications for financial institutions.

FINMA has launched the consultation on the 2026 partial revision of the AMLO‑FINMA, focusing on strengthening sanctions compliance, improving transparency of ownership and control structures, and tightening rules for correspondent banking and sub-accounts. Financial intermediaries will need to review and adapt their governance, KYC processes and control frameworks to align with the updated regulatory requirements and international standards.

With a new national strategy, the Federal Council is taking a clear stand against money laundering and terrorist financing, with a focus on transparency, law enforcement, asset recovery and cooperation.

In May 2024, we reported on the planned EU anti-money laundering package, consisting of a directive and three regulations. The aim is to harmonise and strengthen EU anti-money laundering regulations. Where do we stand today, approximately a year and a half after it came into force? Which regulations are already in place, and what can member states and financial institutions expect in the future? Below is a concise overview of the current status and timetable for the AML package.

After years of negotiations, Switzerland and the United States of America (USA) signed a new FATCA (Foreign Account Tax Compliance Act) Agreement on 27 June 2024.

There are currently interesting developments in Anti-money laundering legislation in the European Union (EU). The crypto sector and dealers of luxury goods such as cars, works of art, yachts, jewellery, etc. will be affected heavily by the future regulations. Professional football clubs and agents are also expected to be affected. In addition, an EU-wide upper limit for cash payments of a maximum of EUR 10,000 and a new EU authority to combat money laundering are to be created. This article outlines the most important changes at EU level, which could also have an impact on Swiss Anti-money laundering legislation in the medium term.