Revised Anti-Money Laundering Act · from 1 October 2026

Does the new AMLA duty from October 2026 also apply to you?

The revision of the Anti-Money Laundering Act places advisory professions under obligation for the first time. Whether fiduciary, law firm, notary or real estate — we help you find out what applies to you and guide you step by step.

Clarity in minutes — explained plainly, without jargon.

Grounded in Swiss law Transparent & verifiable Hosted in Switzerland
Entry into force
1. Oktober 2026
Days
Hrs
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Anyone newly in scope must join within two months of the reference date to a FINMA-recognised SRO.
The revision in brief

What the revision changes

Switzerland is stepping up its anti-money-laundering efforts, following the FATF recommendations. Advisory activities now also come into focus. The essentials at a glance — adopted on 26 September 2025, effective from 1 October 2026.

Advice becomes regulated

Anyone who sets up companies, plans structures, manages trusts or foundations, or takes part in real-estate purchases may now be included.

new scope

Look more closely

Who really stands behind a client must be clarified more rigorously in future — especially with multi-tier ownership.

Art. 3 & 4 AMLA

Risk sets the pace

The trickier the setup — PEP, domiciliary company, opaque chain — the more thoroughly origin and purpose are examined.

Art. 6 AMLA

Joining an SRO

There's no way around self-regulation: those in scope join a FINMA-recognised organisation — promptly after the reference date.

SRO · FINMA oversight
Scope

Who's now included — and who isn't

It's not the title on your business card that counts, but what you actually do. Transaction-related advice with heightened risk is covered; simply practising your profession stays out of scope.

covered This triggers a duty

Setting up & restructuring companies
Founding, organising or selling a company — including domiciliary companies.
Trusts & foundations
Creating, running or dissolving such entities.
Real-estate deals
Taking part in the purchase or sale of land and property.
Buying & selling companies
Advising on and handling share or asset deals.
Managing assets & accounts
Handling client funds, accounts or securities.

excluded This stays untouched

Representation in court
Classic advocacy before courts and authorities.
Family & inheritance matters
Matters unrelated to a transaction.
Mere legal information
Advising without taking part in a financial transaction.
Minor cases
Transactions below the thresholds set by the ordinance.
For lawyers and notaries, special safeguards apply during SRO supervision to preserve professional secrecy.
When the duty applies

These duties apply when you're in scope

If you're affected, five things must run continuously and be properly documented. Add to that joining an SRO and a report as soon as something looks off.

1

Identify the counterparty Art. 3 AMLA

Who's across the table? For individuals a valid ID suffices, for companies a current register extract — record and file it.

2

Who's behind it? Art. 4 AMLA

Behind every company there are people. From 25 percent control — or influence by other means — you should know who that is.

3

Does the picture add up? Art. 6 AMLA

Does the business fit the client? The purpose of the relationship and the source of funds should be plausible — especially thoroughly where risk is heightened.

4

Stay on it

A business relationship doesn't end after the first meeting. Keep the details current and watch for anything unusual.

5

Record & retain Art. 7 AMLA

What isn't documented counts as not having happened when it matters. Records stay accessible for ten years beyond the end of the engagement.

Report on suspicion Art. 9 AMLA

If a suspicion hardens, there's no way around a report — it goes through the MROS portal goAML.

Timeline & risks

Deadlines and what else is at stake

The date is set. Anyone who only wakes up on 1 October quickly falls behind — on joining an SRO and on documentation.

26. September 2025

Passed by Parliament

The National Council and Council of States pass the revision, including the Transparency Act (TJPG).

12. Juni 2026

The Federal Council gets going

The Federal Council sets the start date and adopts the implementing ordinances.

1. Oktober 2026

It applies

The revised AMLA and the transparency register are in force — the due-diligence obligations apply.

+ 2 months

SRO on board

By then, membership of a FINMA-recognised SRO must be in place.

What doing nothing can cost

Intentionally neglectedup to CHF 500,000
Through negligenceup to CHF 150,000
From the supervisorFINMA proceedings
In serious casesProfessional ban
And not to be underestimatedReputation & trust
Penal provisions Art. 37 AMLA
From check to ongoing cockpit

Compliance you can account for

No one-off PDF, no opaque machine. First clarity on whether it affects you — then a tool for everyday use and specialists when things get tricky.

Step 1 · free

Scope check

A few targeted questions about your work are enough. The result is a clear answer — with reasoning and a reference to the relevant legal provision.

  • Open logic, not a black box
  • Every answer is justified
  • Done in a few minutes
Start the check
Cockpit
Step 2 · ongoing

Due-diligence cockpit

All engagements clearly in one place: identification, beneficial owners, risk classification, documentation, MROS preparation and a complete audit trail.

  • Ongoing, not one-off
  • Risk indicator & progress at a glance
  • History & 10-year archive included
Reserve access
Step 3 · if needed

Personal review

Your case isn't clear-cut? Our Swiss specialists review it personally and also support you in joining an SRO.

  • Real people, not a machine
  • Support all the way to SRO membership
  • Fiduciary & legal experience
Request advice
Why not an AI machine?  When FINMA, an SRO or criminal authorities ask, you must be able to explain every assessment. Disclosed, rule-based logic can be reviewed — a black box cannot.
Who for

Who this helps

FiduciariesFormation, administration, structuring
Lawyers & notariesTransaction-related engagements
Real-estate agentsPurchases and sales of property
Management consultantsM&A and structuring
Accounting & family officesManaging assets and accounts
SROs & associationsOn request for your members
Guide

Background reading

Frequently asked

Answered briefly and clearly

What does the revision actually bring?
For the first time, advisory professions are also covered when they take part in sensitive dealings — such as setting up or selling companies, trusts and foundations, or real estate. Anyone previously out of scope may be included from 1 October 2026.
Am I even affected?
What's decisive is not your job title but your activity. If you professionally do something the expanded scope names, you may be subject to it. The check walks you through the relevant questions and tells you where you stand.
Which duties will I face?
Five core points: identify the counterparty, clarify the true owners, check the background and source of funds, keep an eye on the relationship and retain everything for ten years. Plus joining an SRO and a report to MROS as soon as a suspicion arises. Art. 3, 4, 6, 7, 9 AMLA
Do I really have to join an SRO?
Yes — for those in scope, nothing works without membership of a FINMA-recognised self-regulatory organisation. It ensures the due-diligence obligations are met. Membership must be in place shortly after the reference date; for lawyers and notaries there are special rules protecting professional secrecy.
And if I simply do nothing?
In the best case nothing happens — in the worst it gets expensive. Possible outcomes include FINMA proceedings, six-figure fines, in serious cases a professional ban, and real damage to reputation and trust. Art. 37 AMLA
Isn't this the same as the transparency register?
No, these are two different things. The transparency register obliges the company itself to report its true owners centrally. You as an adviser remain independently obliged to check the same people yourself — and to pass on any discrepancies within 30 days.
Is there artificial intelligence behind it?
No. The check runs on open, verifiable logic derived directly from the law. Every result can be justified and backed by the relevant provision — exactly what matters when you're reviewed.

Get clarity

Take the check or have your case reviewed personally. For borderline cases, licences for associations or simply open questions, we're here for you.

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