Swiss AML Reform 2026: New Duties for Advisers and Stronger Ownership Checks

Executive Overview

Switzerland's revised Anti-Money Laundering Act enters into force on 1 October 2026, alongside the new transparency legislation. For professional-services firms, the most significant development is the extension of due-diligence requirements to certain advisory activities regarded as carrying higher money-laundering risk. The reform does not convert every adviser into a financial intermediary, but it does require each firm to determine, service by service, where the revised perimeter falls.

The practical consequence is a classification exercise followed by a proportionate redesign of controls. Firms that begin with process redesign before establishing which mandates are actually in scope tend to over-engineer some areas while leaving genuine exposure unaddressed.

Regulatory Background

In parallel with the statutory reform, FINMA has launched a partial revision of its Anti-Money Laundering Ordinance. The proposed adjustments place greater emphasis on understanding the ownership and control structure of clients, and strengthen measures designed to prevent breaches of coercive measures under the Embargo Act. The ordinance work also reflects the amendments to the AML Act and the recommendations of the Financial Action Task Force.

Read together, the statutory and ordinance changes point in a consistent direction: identification of the persons behind a structure, documented risk assessment, and the ability to demonstrate that the assessment was applied rather than merely recorded. The transparency register reinforces the same expectation from the corporate side, which is why the two reforms should be addressed as one programme rather than two.

Why It Matters

The reform is relevant well beyond regulated financial institutions, and its effect is felt most acutely by firms whose mandates sit at the boundary between ordinary consulting and structuring work.

• Advisory, fiduciary and corporate-services firms whose mandates may involve the formation, administration or transfer of legal entities or asset structures.
• Entrepreneurs and investors, who should expect deeper questions on the origin of funds and on the rationale of a proposed structure.
• International families and family offices, whose arrangements often combine several jurisdictions and instruments and therefore attract closer review.
• Swiss and foreign companies engaged in cross-border transactions where sanctions and coercive-measures exposure must be screened.
• Groups relying on external providers, who will need assurance that those providers have adapted their own controls.

Practical Issues to Review

1. 01Classify services and client situations to identify which mandates fall within the revised perimeter and which do not.
2. 02Review onboarding and beneficial-owner identification procedures, including the evidence retained for each determination.
3. 03Reassess risk classification criteria so that higher-risk situations are separated from routine engagements on a documented basis.
4. 04Strengthen sanctions and coercive-measures screening, including the point in the process at which screening is performed and repeated.
5. 05Update engagement letters, internal responsibility matrices and escalation paths so that accountability is explicit.
6. 06Plan training and file-review cycles that evidence consistent application of the framework, not only its existence on paper.

TCC View

TCC's view is that classification precedes process. A firm that knows precisely which of its services could fall within scope can calibrate its controls proportionately, defend that calibration, and avoid imposing financial-intermediary procedures on mandates that do not require them.

We would also address the AML reform and the beneficial-ownership register in a single review. Both rest on the same underlying question — who stands behind the structure and who controls it — and answering it once, properly documented, serves both regimes and the firm's banking relationships at the same time.

Planning Note

The FINMA ordinance revision is still in progress, so certain operational details remain to be confirmed. Firms should complete their scoping and documentation work in advance, while leaving room to adjust procedures once the final ordinance text is available. Where a mandate is genuinely borderline, the prudent approach is to document the reasoning contemporaneously rather than to rely on a retrospective explanation.