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Switzerland AML/CFT Regulation

A reference guide to Switzerland's anti-money-laundering and counter-terrorist-financing framework: FINMA and the self-regulatory-organisation model, the history of the AMLA (GwG), the SECO sanctions regime, and the 2025 transparency reforms.

Last updated 2026-06-20

Switzerland AML/CFT Regulation

Switzerland runs a dual supervisory model: a single AML statute (the Anti-Money Laundering Act, AMLA / GwG) applied through a mix of direct FINMA supervision and self-regulatory organisations (SROs) that supervise non-banking financial intermediaries. The Financial Intelligence Unit sits inside the federal police, and sanctions are administered separately by SECO under the Embargo Act. This guide summarises the responsible bodies, the legislative history, and the core obligations placed on financial intermediaries.

Swiss AML/CFT bodies and roles

BodyRole
FINMA (Swiss Financial Market Supervisory Authority)AML supervisor for banks, securities firms, insurers, fund managers, and DLT/crypto trading venues; issues the AMLO-FINMA ordinance (SR 955.033.0) and AML circulars. Independent integrated regulator established under FINMASA (2007/2009).
MROS (Money Laundering Reporting Office Switzerland)Switzerland's Financial Intelligence Unit; receives and analyses suspicious activity reports, forwards them to prosecutors, and exchanges information with foreign FIUs (Egmont Group). Hosted within the Federal Office of Police (fedpol); operates the goAML platform.
SECO (State Secretariat for Economic Affairs)Administers sanctions and embargoes under the Embargo Act; maintains the consolidated sanctions list and the SESAM search tool; receives asset-freeze reports.
SROs (self-regulatory organisations)Supervise the AML compliance of financial intermediaries in the parabanking / non-banking sector; recognised and overseen by FINMA. A defining feature of the Swiss model.
State Secretariat for International Finance (sif)Policy and legislative drafting for the AML statute and related reforms.

Switzerland is a founding FATF member and is evaluated directly by FATF. Its fourth-round Mutual Evaluation Report was adopted in December 2016 and set the reform agenda for the following decade.

History timeline

YearLaw / eventWhat it changed
1990Money laundering criminalised in the Criminal Code (art. 305bis); failure of due diligence (art. 305ter)First money-laundering offence in Swiss law; predates the AML statute.
1997/1998Anti-Money Laundering Act (AMLA / GwG, SR 955.0) — adopted 10 Oct 1997, in force 1 Apr 1998A cross-sector AML statute covering the whole financial-intermediary universe (banking and parabanking); created customer-identification, beneficial-owner, record-keeping, and reporting duties; established the SRO model.
1998MROS establishedSwitzerland's FIU stood up within fedpol.
2002/2003Embargo Act (EmbA, SR 946.231), in force 2003The statutory basis for Switzerland to enact sanctions, administered by SECO (a track parallel to AMLA).
2007/2009FINMA created (operational 1 Jan 2009)Merged predecessor regulators into FINMA; consolidated AML supervision of the banking sector and SRO oversight.
2009AMLA revision (terrorist-financing alignment)Extended and clarified CFT reporting; aligned with FATF revisions.
2016AMLA revision implementing the 2012 FATF Recommendations (in force 1 Jan 2016)Tightened beneficial-ownership identification; introduced rules on bearer shares and PEPs; added cash-payment thresholds for dealers in goods and tax offences as a money-laundering predicate.
Dec 2016FATF fourth-round Mutual Evaluation of SwitzerlandIdentified gaps (transparency of legal persons, lawyer/adviser gatekeepers, the NPO sector); set the reform agenda.
2019/2020AMLO-FINMA partial revisionsImplementation detail for customer due diligence, risk management, and crypto/DLT.
2021/2023Revised AMLA adopted 19 Mar 2021, in force 1 Jan 2023Introduced periodic verification and updating of client data for all relationships (risk-based frequency) and clearer reporting duties. A proposed extension to lawyers and advisers was dropped by Parliament in 2021.
2024Federal Council message on corporate-transparency reformProposed a federal transparency register of beneficial owners and an extension of AML duties to advisers.
26 Sep 2025Parliament adopts the Transparency of Legal Entities Act (TLEA / LETA) and a further AMLA revisionCreates a federal UBO register and brings advisers (and certain lawyer/notary acts) into AML scope, with professional-secrecy safeguards.

Current framework

Who is covered. "Financial intermediaries" under AMLA art. 2 — banks, securities firms, fund and asset managers, life insurers, payment and money-services providers, and the broad parabanking sector; DLT trading facilities and crypto are in scope.

Core duties (AMLA / AMLO-FINMA SR 955.033.0):

DutySubstance
Customer identification (CDD)Verify the identity of the contracting party at onboarding.
Beneficial-owner identificationEstablish and document the natural person ultimately controlling the entity or assets.
Ongoing monitoringRisk-based monitoring of business relationships and transactions.
Periodic data reviewSince 1 Jan 2023, periodic verification and updating of client data for all relationships (risk drives frequency and depth).
Special clarificationsEnhanced due diligence for higher-risk relationships, PEPs, and complex or unusual transactions.
Reporting to MROSMandatory suspicious activity reporting on suspicion of money laundering or terrorist financing, filed via goAML, with asset freezing pending MROS analysis.
Records and organisationDocumentation, internal AML controls, training, and a dedicated AML function.

Supervisory model. Directly supervised intermediaries (banks and similar) report to FINMA; non-banking intermediaries must affiliate with a FINMA-recognised SRO, which writes detailed self-regulation, audits members, and can sanction them, with FINMA supervising the SROs.

Penalties. Criminal Code art. 305bis (money laundering) and art. 305ter (lack of due diligence). AMLA provides for administrative measures by FINMA and criminal fines for breach of the reporting duty and other violations; SROs impose contractual and disciplinary sanctions on their members.

Sanctions screening (SECO / Embargo Act)

  • The Embargo Act (EmbA, SR 946.231, in force 2003) is the statutory basis; the Federal Council enacts country and regime ordinances, and SECO administers and enforces them.
  • SECO publishes a consolidated sanctions list and provides the SESAM search tool. Switzerland's lists track UN measures and, as a policy matter, largely mirror EU sanctions (adopted autonomously), alongside Switzerland's own listings. The SECO list closely mirrors the EU list but is not identical — there can be timing differences and autonomous Swiss listings or de-listings.
  • Reporting obligation. Anyone holding or managing funds, or aware of economic resources likely subject to a freeze, must report to SECO without delay; negligent breach of the reporting duty is punishable under the Embargo Act.
  • FINMA dimension. Beyond AMLA, FINMA expects supervised institutions to manage sanctions risk and can take independent freezing measures.

Recent developments (2024–2025)

In September 2025, Parliament adopted the Transparency of Legal Entities Act (TLEA / LETA) together with a further revision of the AMLA.

ItemDetail
TLEA / LETA (Transparency of Legal Entities and Identification of Beneficial Owners Act)Adopted by Parliament 26 Sep 2025. Creates a federal central register of beneficial owners for legal entities, recording entity identifiers and, per beneficial owner, name, date of birth, residence, and the nature and extent of control. Access is for authorities, not a fully public register.
Revised AMLA (2025)Adopted alongside TLEA. Extends AML due-diligence and MROS reporting to "advisers" performing defined gatekeeper acts such as setting up or structuring legal entities. Advisers must affiliate with an SRO, and FINMA maintains a public register of affiliated advisers. Special safeguards preserve lawyer and notary professional secrecy.
DriverAddresses the FATF gaps identified in the 2016 evaluation and aligns Switzerland with EU and global UBO-register trends.

The entry-into-force date for the TLEA and the revised AMLA is set by the Federal Council, which is also to issue the implementing ordinances. As of 20 June 2026, the Federal Council had not yet fixed that date.

Sources and primary authorities

Primary sources accessed 2026-06-20 unless noted.

This guide provides general information only and is not legal advice. Current as of 2026-06-20.

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