Swiss Anti-Money Laundering Act: New Due Diligence Obligations for Advisors and Fiduciary Service Providers from 1 October 2026
The revised Swiss Anti-Money Laundering Act (AMLA) will enter into force on 1 October 2026. Certain professional advisory services will also become subject to anti-money laundering and counter-terrorist financing requirements. The amendments particularly affect activities relating to real estate transactions and the establishment and structuring of legal entities.
Which Activities Are Affected?
Under Article 2 paragraphs 3bis et seq. AMLA, certain advisory services fall within the scope of the Act where the statutory conditions are met. These include in particular:
- Professional involvement in financial transactions relating to the purchase and sale of real estate.
- Certain activities involving the establishment and structuring of legal entities.
- Other services specified by law relating to corporate structures and assets.
Whether an advisor is subject to the AMLA depends on the activities actually performed rather than their professional designation. General accounting, tax advisory or audit services therefore do not automatically fall within the scope of the new requirements for advisors.
New Due Diligence Obligations
Advisors subject to the revised AMLA must comply with the following requirements in particular:
- Identification: Establishing and verifying the identity of clients and beneficial owners.
- Clarification: Determining the nature and purpose of the business relationship or the specific service provided.
- Risk Assessment: Conducting additional investigations where there is an increased risk of money laundering or terrorist financing.
- Documentation: Maintaining appropriate records and retaining the information and supporting documentation required by law.
- Organisation: Implementing appropriate internal controls, allocating responsibilities and providing relevant training.
- Reporting Obligations: Complying with statutory reporting obligations to the Money Laundering Reporting Office Switzerland (MROS), where the applicable legal conditions are met.
The relevant provisions are set out in particular in Articles 8b–8d and 9 AMLA.
Supervision and Self-Regulation
Advisors subject to the revised AMLA must generally affiliate with a recognised self-regulatory organisation (SRO). Compliance with the statutory due diligence obligations will be monitored under the applicable supervisory framework. Special provisions apply to certain professional groups, particularly lawyers and notaries.
Transitional Period
Advisors who are already professionally engaged in activities subject to the new requirements when the revised provisions enter into force on 1 October 2026 must submit an application for membership of a recognised SRO by 1 December 2026 at the latest.
Pending a decision on their application, they may generally continue their activities only within the scope of existing business relationships.
Action Required by Companies and Advisory Service Providers
Fiduciary firms, corporate advisors and other potentially affected service providers should review their services to determine whether they fall within the scope of the AMLA. Particular attention should be paid to the statutory criteria for professional activities and the services actually provided.
Where the new requirements apply, appropriate organisational measures, internal policies, documentation procedures and supervisory arrangements must be established.
The official communications and statutory provisions issued by the Swiss federal authorities shall prevail.
Sources:
https://www.sif.admin.ch/de/geldwaeschereigesetz-gwg
https://www.fedlex.admin.ch/eli/oc/2026/322/de