Insights

On 4 June 2026, FINMA published its Guidance 04/2026, thereby supplementing FINMA Guidance 05/2023 on money laundering risk analysis pursuant to Art. 25 para. 2 AMLO-FINMA. The Guidance is based on FINMA’s inspections of banks and FINIA institutions and clarifies its expectations regarding the content, methodology and control function of the risk analysis.

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.

This article provides an overview of the implementation of the EU Anti-Money Laundering (AML) Package in Liechtenstein, including the repeal of the current SPG and the introduction of the new Anti-Money Laundering Act (AMLA). It outlines the key regulatory changes affecting financial and non-financial entities, highlights the expanded scope of obliged entities, and explains stricter due diligence, reporting, and compliance requirements. The article also addresses the role of supervisory authorities, updated risk classification rules, and the expected timeline for implementation, helping market participants assess their readiness and adapt their internal AML frameworks accordingly.

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.

Even without specific AI legislation, Swiss financial institutions are now responsible for managing their use of AI appropriately.

On 25 February 2026, the Federal Council decided to adopt the additional measures of the EU’s 19th sanctions package against Russia. With its entry into force on 26 February 2026, Switzerland has, for the first time, introduced a fully developed sanctions framework specifically covering the crypto sector. The new rules apply to all financial intermediaries and are particularly relevant for institutions with crypto exposure.

On 22 October 2025, the Federal Council opened the consultation procedure on an amendment to the Financial Institutions Act (FinIA). The plan is to introduce two new licence categories – payment institutions and crypto institutions – with the objective of enhancing the attractiveness of Switzerland as an economic and financial centre and improving the integration of innovative financial technologies into the existing financial system. In the context of the proposed FinIA amendments, other financial market laws (FinSA, AMLA, FINMASA, FinMIA) are also to be amended.

GTRegs is a regulatory monitoring tool for the Swiss financial market. It supports board members, executives, risk and compliance officers at regulated financial institutions in systematically classifying regulatory developments.

In March 2024, we launched our matchmaking platform for asset managers. It was developed with the aim of giving asset managers free access to Grant Thornton's extensive network and thus providing them with targeted support in their search for suitable partnerships. Almost two years have passed since then, making this an ideal time to give you an insight into the status and the latest developments.

On December 16, 2025, FINMA opened the consultation on an amendment to FINMA Circular 2016/7 "Video and online identification." The aim is to adapt the existing regulations to technological developments and new legal requirements. In particular, the Federal Act on Electronic Identification Services ("e-ID Act"), which is expected to come into force in mid-2026, will be taken into account. The changes are relevant for all financial service providers who identify new customers electronically.

A little over two years after the revised data protection legislation came into force, and with a wealth of implementation experience under our belts, most people are now much more aware of the complexity of the subject matter. This article highlights areas where the Federal Data Protection and Information Commissioner (FDPIC) has identified a need for action in the course of its supervisory activities, the data protection risks that can be gleaned from the recently published FINMA Risk Monitor 2025, and the challenges this poses for financial institutions. It then briefly discusses data protection aspects of the use of artificial intelligence (AI).

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.

Qualified participants, managing directors or board members of banks and other financial institutions that are licensed and supervised by FINMA will remember the forms with the inconspicuous designations B1, B2 and B3.

Unpredictable events or legal violations can suddenly plunge companies and their managers into a crisis situation.

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.