Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Switzerland CH

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

Largely CompliantTier ARisk: StableMixed

Switzerland's AML/CFT regime rests on the Anti-Money Laundering Act (GwG), FINMA supervision, and MROS reporting.

FATF rates it compliant/largely compliant on 37 of 40 recommendations, but beneficial ownership transparency remains unimplemented, gatekeeper (lawyer/notary) AML duties are limited, and Banking Act Article 47 secrecy provisions chill investigative disclosure.

Key deficiencies

No operative federal beneficial ownership register despite a 2023 draft bill
Lawyers, notaries and fiduciaries largely outside AML due-diligence obligations
Banking Act Article 47 criminalises disclosure of client data, deterring whistleblowing and press scrutiny
FINMA historically lacked power to directly fine banks (reform only proposed mid-2025)
Geneva/Zug commodity-trading hub structurally exposed to sanctions-evasion intermediation

Recent developments (18m)

FINMA investigation into Bank Reyl's handling of high-risk PEP accounts revealed via leaked correspondence (April 2025)
SECO raid on metals trader Open Mineral AG over Russian gold sanctions breaches (September 2025)
Federal Council proposal to grant FINMA bank-fining powers (June 2025)
OFAC-SECO Memorandum of Understanding on sanctions cooperation (May 2025)
Swiss Supreme Court ruling on unlawful confiscation method in the Magnitsky-linked case (December 2025) followed by a Council of Europe Parliamentary Assembly resolution rebuking Switzerland's failure to act (April 2026)
MBaer Merchant Bank shut down and placed under preliminary Swiss criminal probe following US money-laundering allegations tied to Iran (April 2026)

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Switzerland's financial-integrity architecture moved on its own domestic timetable this cycle rather than through a sanctions event. On 1 October 2026 the Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners (TJPG) and the revised Anti-Money Laundering Act (GwG, SR 955.0) entered into force together. The Federal Office of Justice began live operation of the country's first-ever central federal Transparency Register the same day, following a pilot phase that involved roughly 2,500 companies, with the beneficial-ownership threshold set at natural persons controlling more than 25 percent of capital or voting rights. The timing is not incidental: Switzerland's fifth-round FATF mutual evaluation has an on-site period possibly in June 2027 and a plenary discussion possibly in February 2028, and the Federal Council appears to have sequenced commencement of both instruments to allow effectiveness to be demonstrated ahead of that assessment window.

Alongside the register, the revised GwG extends the anti-money-laundering perimeter to professional advisers, including lawyers, notaries, fiduciaries, and mergers-and-acquisitions or company-formation advisers, on an activity basis across five trigger categories. This closes a long-flagged enabler-jurisdiction gap, though the specific professional-activity thresholds reported this cycle rest on secondary legal commentary rather than a directly retrieved statutory text, and should be read as probable rather than confirmed pending direct verification against the Fedlex GwG and AMLO provisions.

Other Developments

Sanctions posture holds steady. Switzerland's standing sanctions position remains the Federal Council's implementation of the EU's 20th sanctions package on 19-20 August 2026, under the Ukraine Ordinance framework. No new Switzerland-specific designation was dated within this window, though UN Panel of Experts and OFAC/OFSI Houthi-linked sanctions channels were not actively queried this cycle, so this should be read as a coverage gap rather than a confirmed no-change finding for that sub-channel.

Crypto licensing framework remains in consultation. The Financial Institutions Act amendment proposing new Payment Instrument Institution and Crypto-Institution licence categories had its consultation close on 6 February 2026, with entry into force expected not before 2027. No new in-window development moved this file forward this cycle; it remains a pending structural shift that would move affected custody, trading, and stablecoin-issuance firms from self-regulatory-organisation oversight toward direct prudential supervision by FINMA.

Structural distinction from the EU framework persists. Switzerland remains a member of the European Free Trade Association but not the European Economic Area, so the EU's AML Regulation, sixth Anti-Money Laundering Directive, and AMLA Regulation carry no transposition obligation into Swiss law. The reforms taking effect this cycle are autonomous national measures assessed directly by FATF rather than EU-driven transposition.

Cross-Monitor Connections

The commencement of Switzerland's beneficial-ownership register and the extension of AML duties to professional advisers intersect with corporate-transparency and enabler-jurisdiction questions that the data-protection monitor also tracks from a different angle, particularly around what information the Transparency Register holds and who may access it. The pending Crypto-Institution licence category is relevant to crypto-monitor coverage of Swiss digital-asset custody and stablecoin-issuance supervision, since it would shift oversight from self-regulatory bodies to direct FINMA prudential supervision.

Outlook

The near-term marker to watch is whether the Federal Council or FINMA issues implementing guidance clarifying the professional-activity thresholds for the adviser AML perimeter, which would move that finding from probable to confirmed. Further out, the FATF fifth-round mutual evaluation, with an on-site period possibly in June 2027 and plenary discussion possibly in February 2028, will test whether the new Transparency Register and adviser-perimeter extension translate into measured effectiveness rather than formal compliance alone. The FinIA licensing reform remains a slower-moving structural item, with entry into force not expected before 2027.

weekly_brief_draft · JID CH

Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership and Corporate Transparency

Beneficial Ownership and Corporate Transparency

Switzerland's long-standing absence of a central beneficial-ownership register ended on 1 October 2026, when the Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners (TJPG) entered into force alongside the revised Anti-Money Laundering Act (GwG, SR 955.0). The Federal Office of Justice began live operation of the Transparency Register the same day. This is a structural development rather than an incident: Switzerland now holds a federal mechanism recording natural persons who control more than 25 percent of a legal entity's capital or voting rights, built on experience from a pilot phase involving roughly 2,500 companies. For a jurisdiction long identified in FATF commentary as lacking a central beneficial-ownership mechanism, this closes a durable architectural gap rather than resolving a single enforcement episode.

The register's commencement is directly linked to the broader enabler-jurisdiction reform taking effect the same day. The revised GwG simultaneously extends the anti-money-laundering perimeter to lawyers, notaries, fiduciaries, and mergers-and-acquisitions or company-formation advisers on an activity basis across five trigger categories, a professional-facilitator population historically associated with layering beneficial ownership behind complex corporate and trust structures. Read together, the register and the adviser-perimeter extension form a single architectural move: the register creates the record, and the extended adviser perimeter creates obligations on the professionals who structure the entities the register now has to capture. The adviser-side threshold detail rests on secondary legal commentary rather than a directly retrieved statutory provision, so the precise activity thresholds triggering adviser obligations should be treated as probable rather than confirmed pending direct verification against the Fedlex text.

The timing bears directly on Switzerland's international standing. The Federal Council's sequencing of these two instruments appears designed to allow Switzerland to demonstrate effectiveness of its beneficial-ownership and corporate-transparency architecture ahead of its fifth-round FATF mutual evaluation, with an on-site period possibly in June 2027 and plenary discussion possibly in February 2028. Switzerland's fourth-round follow-up assessment in 2023 rated it Compliant or Largely Compliant on 37 of 40 FATF Recommendations, and beneficial ownership transparency has historically been among the areas evaluators scrutinise most closely for enabler jurisdictions with large wealth-management and trust-administration sectors.

It is worth noting explicitly that Switzerland's reform is autonomous rather than derivative. As a member of the European Free Trade Association but not the European Economic Area, Switzerland has no transposition obligation under the EU's AML Package, meaning the Transparency Register and GwG revision were built and sequenced according to Switzerland's own domestic and FATF-facing timetable rather than as downstream implementation of the EU AML Regulation, the sixth Anti-Money Laundering Directive, or the AMLA Regulation. This distinguishes the Swiss reform from the parallel architectural shift under way inside the EU, where a hybrid national/EU-level supervisory model is emerging under the new Anti-Money Laundering Authority; Switzerland's register and GwG revision sit entirely within a national supervisory perimeter, with FATF rather than any EU body as the external evaluator.

Outlook

The register's live operation marks commencement, not completion. The near-term question is one of operational maturity: how comprehensively the roughly 2,500-company pilot population scales to the full universe of Swiss legal entities, and whether the Federal Office of Justice publishes implementing guidance on verification and update obligations for beneficial-ownership data. The adviser-perimeter extension carries its own six-month self-regulatory-organisation affiliation clock, the practical effect of which this cycle's substrate does not resolve beyond the law and commentary already cited. The structural marker to watch across the medium term remains the FATF fifth-round evaluation window, where the register and the adviser perimeter will be tested for effectiveness, not merely formal existence, against the FATF Recommendations.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

Switzerland's revised Anti-Money Laundering Act (GwG, SR 955.0), in force from 1 October 2026 alongside the Transparency of Legal Entities and Identification of Beneficial Owners Act (TJPG), extends the anti-money-laundering perimeter to a population of professional facilitators that has historically sat outside direct AML obligation in Switzerland: lawyers, notaries, fiduciaries, and mergers-and-acquisitions or company-formation advisers. This is a classic enabler-jurisdiction correction. Jurisdictions with sophisticated professional-services sectors are frequently assessed by FATF not on whether their banks apply customer due diligence, but on whether the professionals who structure, register, and administer legal entities on behalf of clients are themselves subject to equivalent obligations. Switzerland's revision brings these advisers into scope on an activity basis across five distinct trigger categories, rather than a status-based test applying to the profession as a whole, which means obligation turns on what work is actually performed rather than who performs it.

The reported detail of how that activity test operates, including professional-activity thresholds and a six-month deadline for affiliation with a self-regulatory organisation, derives from secondary legal commentary rather than a directly retrieved Fedlex statutory text this cycle, and should accordingly be read as probable rather than confirmed. Court and administrative representation work reportedly remains carved out of the extended perimeter, consistent with long-standing distinctions in comparable regimes between advisory and transactional work, which attracts AML scrutiny, and litigation representation, which generally does not. Architecturally, this is significant regardless of the precise threshold figures: it signals that Switzerland has moved from a narrower financial-intermediary-centred AML perimeter toward one that captures the professional-facilitator layer directly, closing a gap that has been a recurring theme in evaluations of enabler jurisdictions with large wealth-structuring sectors.

The reform does not stand alone. It commenced on the same day as the Transparency Register under the TJPG, and the two instruments are structurally linked: the professionals newly brought into the AML perimeter are frequently the same actors who establish and administer the legal entities whose beneficial owners the new register is designed to capture. Viewed together, Switzerland has moved on both sides of the enabler-jurisdiction equation in a single commencement date, rather than sequencing entity transparency and facilitator obligation separately.

The sequencing is also plainly oriented toward Switzerland's upcoming FATF assessment cycle. With the fifth-round mutual evaluation carrying an on-site period possibly in June 2027 and a plenary discussion possibly in February 2028, bringing the adviser perimeter into force well over a year in advance gives Switzerland a demonstrable track record of enforcement and compliance activity under the new rules by the time assessors arrive, rather than a freshly enacted provision with no operating history.

Outlook

The principal open question is verification of the specific activity thresholds governing when an adviser falls inside the AML perimeter, since this cycle's finding rests on secondary commentary rather than the primary statutory or ordinance text. Confirmation of those thresholds, and of how the six-month self-regulatory-organisation affiliation deadline is being administered in practice, would move this finding from probable to confirmed. Over the medium term, the test will be whether self-regulatory organisations onboard the newly captured adviser population in substance, with real due-diligence and reporting activity, ahead of the fifth-round FATF evaluation window, or whether the extension remains largely formal in its first year of operation.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Switzerland's AML/CTF regime of record moved materially this cycle with the simultaneous entry into force, on 1 October 2026, of the revised Anti-Money Laundering Act (GwG, SR 955.0) and the new Transparency of Legal Entities and Identification of Beneficial Owners Act (TJPG). Together these instruments extend obliged-entity scope to professional advisers on an activity basis and establish Switzerland's first-ever central federal beneficial-ownership register, administered by the Federal Office of Justice and operational from the commencement date following a pilot phase covering roughly 2,500 companies. This is the dominant financial-integrity development for Switzerland this cycle, and it is a structural regime change rather than a sanctions or enforcement event.

A defining structural fact frames how this reform should be read: Switzerland is a member of the European Free Trade Association but not the European Economic Area, and therefore carries no transposition obligation under the European Union's AML Package, meaning the AML Regulation, the sixth Anti-Money Laundering Directive, and the AMLA Regulation establishing the Anti-Money Laundering Authority do not reach Swiss law. Switzerland's AML/CTF regime is instead assessed directly by the Financial Action Task Force under its own methodology, independent of the EU's emerging hybrid national/EU-level supervisory architecture. The October reforms are accordingly an autonomous national response to FATF-facing gaps rather than downstream implementation of any EU instrument.

That FATF-facing dimension gives the reform its timing logic. Switzerland's fifth-round mutual evaluation carries an on-site period possibly in June 2027 and a plenary discussion possibly in February 2028. Switzerland's fourth-round follow-up evaluation in 2023 rated the country Compliant or Largely Compliant on 37 of the 40 FATF Recommendations, and beneficial-ownership transparency and professional-facilitator coverage have been persistent areas of scrutiny for jurisdictions with large wealth-management sectors. Bringing both the Transparency Register and the extended adviser perimeter into force well over a year ahead of the on-site assessment window gives Switzerland an operating track record to present to evaluators, rather than untested legislation.

Outside this structural reform, the broader AML/CTF picture for Switzerland was stable this cycle. The country's sanctions posture remains anchored to the Federal Council's implementation of the European Union's 20th sanctions package on 19-20 August 2026 under the Ukraine Ordinance framework, with no new Switzerland-specific designation dated within this window, though UN Panel of Experts and OFAC/OFSI Houthi-linked sanctions channels were not actively queried this cycle and this absence of finding should be read as a coverage gap rather than a confirmed no-change position. The proposed Financial Institutions Act amendment creating new Payment Instrument Institution and Crypto-Institution licence categories, with its consultation closed since 6 February 2026, also remains pending, with entry into force not expected before 2027.

Outlook

The principal marker ahead is operational: whether the Transparency Register's data proves verifiable and current as its population scales beyond the roughly 2,500-company pilot, and whether the extended adviser perimeter generates substantive due-diligence and reporting activity among newly captured lawyers, notaries, and fiduciaries rather than nominal self-regulatory-organisation affiliation alone. The structural test of this cycle's reforms will come with the FATF fifth-round mutual evaluation, with its on-site period possibly in June 2027 and plenary discussion possibly in February 2028, which will assess effectiveness rather than formal enactment. The pending Financial Institutions Act licensing reform remains a separate, slower-moving structural item on the horizon, not expected to take effect before 2027.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon

Consultation2027 · ±year

FinIA Payment Instrument Institution / Crypto-Institution licence categories

Replaces the CHF 100m-capped fintech licence with an uncapped Payment Instrument Institution licence and creates a new Crypto-Institution licence; moves affected firms to direct FINMA supervision.

Source

Proposed2027-Q2 · ±year

FATF 5th-round mutual evaluation of Switzerland

CH's AML/CFT effectiveness, including the new BO register and adviser perimeter, will be tested against FATF's 40 Recommendations under the 5th-round methodology.

Source

2 dated · 4 pending date · baseline fim-2026-07-08

Role action cards

MLRO

Switzerland's revised GwG and TJPG entered into force 1 October 2026, extending AML perimeter to professional advisers and launching the federal beneficial-ownership register.

Swiss-facing institutions should note that lawyers, notaries, fiduciaries, and company-formation advisers are now within the activity-based AML perimeter, which may affect correspondent and intermediary due-diligence expectations for Swiss counterparties. The beneficial-ownership register's commencement also changes the information landscape for Swiss corporate structures.

3 evidence refs

Compliance

Switzerland's AML/CTF regime moved structurally this cycle ahead of its FATF fifth-round evaluation.

The commencement of the Transparency Register and the adviser-perimeter extension signal that Switzerland is actively closing FATF-flagged gaps; compliance functions monitoring enabler-jurisdiction exposure to Switzerland should track how these obligations are enforced in practice.

3 evidence refs

Legal

Swiss GwG extension brings lawyers, notaries, and fiduciaries into the AML perimeter on an activity basis from 1 October 2026.

Legal counsel advising Swiss-facing structures should note the extended adviser perimeter and the reported carve-out for court and administrative representation, though the specific activity thresholds remain sourced to secondary commentary rather than a confirmed statutory text this cycle.

1 evidence refs

Board

Switzerland's new beneficial-ownership register and extended AML adviser perimeter represent a structural regime shift ahead of FATF review.

This is a jurisdiction-level architectural change rather than an isolated enforcement incident, timed ahead of Switzerland's fifth-round FATF mutual evaluation; institutions with material Swiss exposure should be aware the regulatory baseline has moved.

3 evidence refs

CTO

Swiss FinIA Crypto-Institution licence category remains in consultation, with entry into force not expected before 2027.

No in-window technical or platform change occurred this cycle; the pending licence category would eventually move affected crypto custody and stablecoin-issuance infrastructure from self-regulatory to direct FINMA prudential supervision.

1 evidence refs

Risk

Switzerland's risk direction on beneficial ownership and enabler-jurisdiction exposure is improving following the 1 October 2026 reforms.

The register and adviser-perimeter extension reduce structural enabler-jurisdiction risk associated with Swiss corporate and trust structuring; the sanctions posture remains stable but carries a noted coverage gap on UN Panel of Experts and OFAC/OFSI Houthi-linked channels.

3 evidence refs

Operations

No material change this cycle.

No material change for this persona this cycle

Audit

Swiss beneficial-ownership register commencement creates a new documentary record relevant to audit trails for Swiss-linked entities.

The Transparency Register's live operation from 1 October 2026 introduces a federal record against which beneficial-ownership documentation for Swiss entities can increasingly be tested, though the adviser-perimeter threshold detail remains unverified against primary statutory text this cycle.

2 evidence refs

Decision lens

MLRO

Switzerland's revised GwG and TJPG entered into force 1 October 2026, extending AML perimeter to professional advisers and launching the federal beneficial-ownership register.

Compliance

Switzerland's AML/CTF regime moved structurally this cycle ahead of its FATF fifth-round evaluation.

Legal

Swiss GwG extension brings lawyers, notaries, and fiduciaries into the AML perimeter on an activity basis from 1 October 2026.

Board

Switzerland's new beneficial-ownership register and extended AML adviser perimeter represent a structural regime shift ahead of FATF review.

CTO

Swiss FinIA Crypto-Institution licence category remains in consultation, with entry into force not expected before 2027.

Risk

Switzerland's risk direction on beneficial ownership and enabler-jurisdiction exposure is improving following the 1 October 2026 reforms.

Operations

No material change this cycle.

Audit

Swiss beneficial-ownership register commencement creates a new documentary record relevant to audit trails for Swiss-linked entities.

Shared evidence: 3 refs

Scenario sketches

AMLA transition and cross-border supervisory divergence illustrative sketch

Illustrative scenario for analytical orientation only. As the EU moves from purely national AML supervision toward direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AMLR (Reg 2024/1624) and per-state 6AMLD transposition, a structural divergence could emerge between EU-supervised groups and non-EEA jurisdictions such as Switzerland that remain outside this perimeter. One illustrative pathway: a financial group with both EU and Swiss operating entities could face a hybrid EU-level AMLA supervisory touchpoint for its EU business while its Swiss entity remains under purely domestic FINMA and self-regulatory-organisation oversight, creating a possible incentive to route certain cross-border structuring activity through the non-AMLA-supervised entity. This is architecture-over-incident illustration of a possible structural mechanism, not an observed fact or a prediction about any specific institution.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	stable	No new CH-specific designation this window; standing position is the 19-20 Aug 2026 implementation of the EU 20th package.
T2 · EU AML Package / AMLA	no_change	Not applicable to CH as a standing instrument; CH is EFTA but not EEA.
T3 · FATF Grey List	stable	CH not on FATF grey/black list; 5th-round mutual evaluation scheduled (on-site possibly June 2027, plenary Feb 2028).
T4 · Beneficial-Ownership Register Status	improving	CH's first central federal BO register (Swiss Transparency Register) began live operation 1 October 2026.
T5 · Crypto / VASP Regulatory Framework	stable	FinIA consultation on Payment Instrument Institution/Crypto-Institution licences closed 6 Feb 2026; dispatch expected H2 2026/2027, entry into force not before 2027.
T6 · Sanctions Regime Divergence	stable	No new CH-specific divergence event this window; CH tracks EU Russia packages with a lag, retaining Federal Council discretion.

Registers

Enforcement actions

FINMA inspected Bank Reyl in summer 2023 and escalated inquiries to its enforcement division by January 2024 over AML weaknesses and handling of high-risk PEP-linked accounts, including a former Russian minister and associates of Uzbek and Azerbaijani ruling families. 10 Apr 2025
Following a SECO probe, the Office of the Attorney General launched a criminal investigation into potential sanctions violations and money laundering, temporarily freezing CHF 1.65 billion in assets, with CHF 60 million later released after failing to meet the legal freezing threshold. 2 Apr 2025
Swiss authorities raided the Zug office of metals trader Open Mineral AG as part of an investigation into potential sanctions breaches relating to Russian gold trading. 16 Sep 2025
Swiss prosecutors opened a preliminary probe into MBaer Merchant Bank after it was forced to shut down following US authorities' allegations that it facilitated international money laundering linked to Iran. 2 Apr 2026
FINMA told Switzerland's largest consumer trading platform, Swissquote, in an annual assessment letter to reduce the volume of suspicious activity reports it was submitting to the country's money-laundering reporting office. 1 Jul 2025

Sanctions changes

Switzerland adopted further Russia sanctions aligned with the EU's 18th sanctions package, extending restrictions via SECO ordinance amendments. 12 Aug 2025
Switzerland adopted most elements of the EU's 20th sanctions package against Russia and Belarus, targeting energy, third-country banks and crypto providers, but declined to adopt certain elements. 22 May 2026
OFAC published a Memorandum of Understanding with Switzerland's State Secretariat for Economic Affairs (SECO) formalising bilateral cooperation on sanctions implementation and enforcement. 16 May 2025
SECO reported that Russian assets frozen in Switzerland rose to CHF 7.4 billion (a 28% year-on-year increase), including CHF 7.45 billion in Russian central bank reserves, as Switzerland continued incorporating additional EU-aligned Russia designations. 1 Apr 2025

Regulatory horizon (register)

FINMA bank-fining power legislative reform
Federal beneficial-ownership transparency register bill
Financial Institutions Act amendment for crypto/DLT market structure
FATF biennial follow-up update on partially-compliant recommendations

Active schemes

[HIGH] Geneva/Zug commodity-trading conduits for Russian gold and oil
[HIGH] Swiss lawyer/fiduciary network handling Russian shell-company cash flow
[HIGH] Beneficial-ownership opacity via Swiss shell-company registrations
[HIGH] PEP/oligarch private-banking structuring via secrecy-protected accounts
Stablecoin default-guarantee structuring bypassing direct FINMA licensing

Sources

Coverage gaps

Following the Swiss Supreme Court's December 2025 ruling tha…

Following the Swiss Supreme Court's December 2025 ruling that the confiscation method used against Magnitsky-case-linked funds was unlawful, prosecutors did not recalculate or refreeze the assets, allowing them to leave Switzerland; the Council of Europe Parliamentary Assembly passed a 43-7 resolution in April 2026 rebuking Switzerland's handling.

Switzerland has no operative federal beneficial-ownership re…

Switzerland has no operative federal beneficial-ownership register in force; a draft bill has been pending since 2023 with no confirmed enactment date, leaving company and trust ownership opaque outside bank Form-A declarations.

Banking Act Article 47 criminalises disclosure of client ban…

Banking Act Article 47 criminalises disclosure of client banking data, including to journalists exposing wrongdoing; a 2023 parliamentary vote declined to loosen the provision, and prosecutors continue to entertain complaints against journalists (dismissed in December 2025 in the Bank Reyl case).

Prior to the June 2025 legislative proposal, FINMA lacked th…

Prior to the June 2025 legislative proposal, FINMA lacked the power to directly fine banks for regulatory breaches, a capability gap identified as a contributing factor in the agency's failure to pre-empt Credit Suisse's 2023 collapse.

Evidence

Confidence-tiered claims

Swiss Transparency Register began live operation 1 October 2026, administered by the Federal Office of Justice SRC-fim-CH-001

Confirmed · 1 source

Revised Anti-Money Laundering Act (GwG, SR 955.0) entered into force 1 October 2026 alongside the TJPG SRC-fim-CH-002

Confirmed · 1 source

Lawyers, notaries, fiduciaries and M&A/company-formation advisers brought into AML perimeter on an activity basis (five trigger categories), subject to professional-activity thresholds and 6-month SRO affiliation deadline SRC-fim-CH-011

Probable · 1 source

FATF 5th-round mutual evaluation: on-site period possibly June 2027, plenary discussion possibly February 2028 SRC-fim-CH-008

Probable · 1 source

AMLR/6AMLD/AMLA (EU AML Package) does not apply to CH as it is EFTA but not EEA SRC-fim-CH-004

Confirmed · 1 source

FinIA amendment proposing Payment Instrument Institution and Crypto-Institution licence categories; consultation closed 6 Feb 2026, entry into force not before 2027 SRC-fim-CH-010

Confirmed · 1 source

Federal Council implemented EU's 20th sanctions package on 19-20 August 2026; no new CH-specific designation dated in-window SRC-fim-CH-005

Probable · 1 source