Drivers of the revision

FINMA identifies three main drivers for the revision: (i) the revised Anti-Money Laundering Act (AMLA), adopted by Parliament on 26 September 2025 together with the new Federal Act on the Transparency of Legal Entities; (ii) the need to address residual deficiencies identified in Switzerland’s fourth FATF mutual evaluation report and the fourth Enhanced Follow-up Report ahead of the fifth-round evaluation; and (iii) the codification of existing FINMA supervisory practice in the interest of legal certainty.

Key substantive amendments

Ownership and control structure (new Art. 9b). Financial intermediaries must be able to understand the ownership and control structure of the contracting party. The new provision complements existing Art. 9a, under which financial intermediaries must clarify the reasons for the use of domiciliary companies. It responds to FATF criticism (Criterion 10.8 of the 2023 follow-up report) that Swiss law did not contain an express requirement of this kind applicable to all types of companies. Financial intermediaries must ensure that their procedures, client files and audit trails demonstrate that the ownership and control structure of the contracting party has been understood.

Sanctions compliance (new Art. 30). New Art. 30 requires financial intermediaries to implement measures to prevent breaches of coercive measures under the Embargo Act (EmbA). This reflects the revised version of Art. 8 AMLA, adopted by Parliament on 26 September 2025, which expressly requires financial intermediaries to take organisational measures to prevent violations of coercive measures under the Embargo Act (LEmb). The new provision declares Arts. 10, 20, 23, 24, 25, 26 para. 1, 27, 28 and 29 AMLO-FINMA applicable by analogy.

According to FINMA's explanatory report and the Federal Council’s Message on the partial revision of the AMLA and the new Federal Act on the Transparency of Legal Entities, organisational measures include, in particular, the obligation to adopt internal directives and establish a process — or, depending on the size and type of activity of the institution, a computerised system — for screening business relationships, originators and beneficiaries of transactions against sanctions lists. This risk analysis must be carried out periodically and may be integrated into the risk analysis relating to money laundering and terrorist financing.

FINMA further notes that financial intermediaries subject to the AMLO-FINMA are already required to implement such measures under existing requirements for appropriate risk management, including, where applicable, FINMA Circular 2017/1 “Corporate Governance – Banks”, FINMA Circular 2017/2 “Corporate Governance – Insurers”, and FINMA Circular 2023/1 “Operational Risks and Resilience – Banks”.

Correspondent banking and payable-through accounts (revised Art. 37). The revision of Art. 37 para. 5 AMLO-FINMA concerns payable-through accounts, which may be offered within correspondent banking relationships. These are correspondent banking accounts used by foreign financial intermediaries to provide their clients with access to the domestic banking system. The new para. 5 provides that a financial intermediary may execute payments for a customer’s clients via payable-through accounts only if it is ensured that the customer will, upon request, provide the client information necessary to fulfil due diligence obligations, such as transaction details or the KYC profile of end clients. This amendment addresses FATF Recommendation 13 (Criterion 13.2), under which Switzerland was rated non-compliant in 2016, and codifies FINMA’s long-standing supervisory practice.

Sub-accounts for individual clients (new Art. 65 para. 2 let. d). In accordance with Art. 4 AMLA, the beneficial owner must always be identified and their identity verified. The addition of letter d to Art. 65 para. 2 AMLO-FINMA provides that in the case of sub-accounts for individual clients, a declaration regarding the beneficial owner must always be obtained from the contracting party.

Travel rule — Liechtenstein payments (Art. 10 para. 3 repealed). The exemption under which payments to and from Liechtenstein were treated as domestic transfers is repealed. FINMA considers the carve-out obsolete and incompatible with FATF standards, which treat Switzerland–Liechtenstein payments as cross-border transactions.