AMLO-FINMA Revision: The Article-by-Article Changes for 1 January 2027

FINMA published the final partial revision of the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA) on 10 November 2026. The amending decree is dated 29 October 2026 and applies from 1 January 2027. That leaves FINMA-supervised financial intermediaries about seven weeks to bring their AML directives, entity KYC procedures and sanctions controls into line with an ordinance that now requires them to understand each contracting party’s ownership and control structure, and to run their core AML organisation, by analogy, against breaches of Embargo Act sanctions.

The AMLO-FINMA revision follows the revised Anti-Money Laundering Act (AMLA) and the new Transparency Act, both in force since 1 October 2026, and it is timed against Switzerland’s next FATF mutual evaluation. FINMA’s explanatory notes put the FATF on-site visit between May and July 2027 and explain that ordinance changes count in that assessment only if they are in force by the end of the visit. That is the reason FINMA gives for cutting the consultation to less than a month.

Two pieces of self-regulation arrived with the ordinance. FINMA’s Board of Directors recognised VSB 27, the revised agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence, and the revised regulations of the Swiss insurance industry’s self-regulatory organisation (SRO-SVV) as minimum standards. Both start on 1 January 2027 and both carry a four-month transition period, which the ordinance amendment itself lacks. FINMA also issued Guidance 06/2026 on reading Circular 2011/1 now that the AMLA reaches certain advisory services.

Related reading: FINMA Circular 2016/7 Revision: e-ID, QR Codes and Liveness Checks

AMLO-FINMA revision dates: from consultation to the FATF visit

• 12 May to 9 June 2026: FINMA consultation on the draft amending decree.
• 12 June 2026: the Federal Council fixes 1 October 2026 as the start date of the revised AMLA and the Transparency Act, with the provisions on state notaries postponed so the cantons can adapt their law.
• 1 October 2026: the revised AMLA and the Federal Act of 26 September 2025 on the Transparency of Legal Persons and the Identification of Beneficial Owners (SR 955.3) enter into force.
• 23 October 2026: the new SRO-SVV regulation is approved in the SRO-SVV members’ ballot.
• 29 October 2026: FINMA adopts the amendment, its explanatory notes and the consultation results report.
• 30 October 2026: date of the VSB 27 agreement cited in the amended Article 35.
• 10 November 2026: FINMA publishes the final text and Guidance 06/2026.
• 1 January 2027: amended AMLO-FINMA, VSB 27 and the new SRO-SVV regulation in force.
• End of April 2027: the four-month transition periods in VSB 27 and the SRO-SVV regulation run out (calculated from 1 January 2027; neither text prints a calendar date).
• May to July 2027: expected FATF on-site visit, according to FINMA’s explanatory notes.

The provision map: what the amending decree of 29 October 2026 touches

The table sets out the provisions the amending decree of 29 October 2026 amends, inserts or repeals.

Two scoping facts decide who reads which row. Articles 9b and 30 sit in Title 1, the general part, so they reach every intermediary the ordinance covers, and FINMA’s consultation report confirms that Article 9b also applies within Title 5. Articles 56 and 65 sit in Title 5, which covers persons licensed under Article 1b of the Banking Act and financial intermediaries under Article 2(2)(abis) and (dquater) AMLA, that is portfolio managers and trustees, and DLT trading facilities. Banks and securities firms identify contracting parties and establish controlling persons and beneficial owners under VSB 27 by virtue of Article 35, and VSB 27 carries its own rules on doubts (Article 46) and on foreign intermediaries that keep sub-accounts (Article 33(2)).

What moved between the May draft and the final text

Teams that built their gap analysis on the consultation draft of 12 May 2026 have five deltas to absorb. Comparing the two decrees line by line:

• Article 9b. The draft was headed “traceability of the ownership and control structure” and required the intermediary to be able to trace it (“nachvollziehen können”). The final heading is simply “ownership and control structure”, and the verb is “understand” (“verstehen”), the word the FATF used in its 2023 follow-up report on Switzerland.
• Article 30. The draft applied Article 25 in full by analogy. The final text limits the reference to Article 25(1)(a) to (c), (2) and (3), so letters (d) and (e) of paragraph 1, ordering additional investigations under Article 15 and supplying the management body with the decision basis under Article 19, sit outside the list.
• Article 37(5). The draft covered payments for all clients of the respondent and asked only for client information on request. The final text is confined to clients with direct access to the correspondent bank’s accounts, adds the condition that the respondent has met its due diligence duties, and speaks of supporting documents (“Belege”).
• Articles 40(4) and 41(3). Absent from the draft; the final text moves both VSB references to VSB 27.
• Article 56(2). Also absent from the draft. FINMA states it could be added after the consultation because it formalises existing practice.

Eleven respondents agreed to publication of their comments. Most of the substantive resistance came from the Swiss Bankers Association (SBVg), economiesuisse and the leasing SRO (SRO SLV) on Article 9b, and from the SRO-SVV and the asset managers’ association VSV on Article 30.

Article 9b: understanding ownership and control for every contracting party

Article 9b is one sentence: the financial intermediary must understand the ownership and control structure of the contracting party. FINMA ties it to the FATF’s October 2023 follow-up report, which recorded under criterion 10.8 that Switzerland had no explicit provision requiring intermediaries to understand the ownership structure of all types of companies. The existing ordinance covered parts of the ground. Article 9a requires intermediaries to investigate why domiciliary companies are used, and Article 13(2)(h) treats complex structures, such as several domiciliary companies or one with fiduciary shareholders, an opaque jurisdiction, no comprehensible reason, or short-term placement of assets, as an increased-risk criterion.

Article 9b reaches every type of contracting party. FINMA derives it from the general duty in Article 4(1) AMLA to establish the beneficial owner with the care the circumstances require, and applies it to operating companies, domiciliary companies, trusts, other associations of persons and other asset units alike. The SBVg, economiesuisse and the SRO SLV argued that the article ignores the conceptual line between controlling persons of operating companies and beneficial owners of domiciliary companies, and the SBVg and the SRO SLV also doubted that the ordinance was a sufficient legal basis. FINMA rejected both points, relying on the delegation in Article 17(1)(a) AMLA.

The depth of the work is risk-based. FINMA declined to write “risk-based” into the article because Article 6(1) AMLA already anchors that approach for every concretising provision, but it expanded the explanatory notes: the more complex and risk-laden the structure, the more extensive the investigation. Its worked example is a domiciliary company acting as the underlying company of a trust, where the intermediary cannot identify the controlling persons and beneficial owners correctly without understanding the structure. For complex holdings, FINMA says a chart of the domiciliary companies, trusts, operating companies and natural persons involved can help. The article itself sets no form requirement.

The documentation duty is where the article bites. Investigations must be recorded under Article 7 AMLA and Article 22 AMLO-FINMA, with the information collected scaled to the client’s risk. The VSV asked FINMA to state that adequate Article 22 documentation proves compliance; FINMA answered by expanding the notes on documentation instead. The test FINMA’s notes set is whether the intermediary can see which natural persons ultimately control the entity and how that control is exercised.

FINMA’s position is that Article 9b introduces, in principle, no new substantive investigation duty and codifies a practice it had communicated in its 2021 and 2023 annual reports. The SBVg and SRO SLV disputed that any expectation of this breadth had been formulated before. On this reading, the exposure sits in entity files that name beneficial owners without recording how control runs to them, because that “how” is the element the notes now spell out.

Insurers also find the principle in their own rulebook. Article 11b of the new SRO-SVV regulation keeps the consultation draft’s wording, requiring the insurer to be able to trace (“nachvollziehen können”) the contracting party’s ownership and control structure.

Article 30: AML controls applied by analogy to Embargo Act sanctions

The revised AMLA requires intermediaries, through Article 8 read with Article 1, to take organisational measures against breaches of coercive measures under the Embargo Act of 22 March 2002 (EmbA, SR 946.231). Article 30 of the ordinance carries this down a level. It states that the intermediary must provide for measures to prevent such breaches and that Articles 10, 20, 23, 24, 25(1)(a) to (c), (2) and (3), 26(1) and 27 to 29 apply by analogy. FINMA’s explanatory notes describe what each reference means for sanctions:

“By analogy” carries weight here. FINMA says the referenced provisions apply adapted to the specifics of sanctions, and its consultation report agrees with respondents that AML transaction monitoring runs ex post while Embargo Act compliance has to be checked ex ante. The notes add that sanctions always count as increased risks. The SRO SLV and the VSV asked FINMA to drop the Article 20 reference because it mixes ex post and ex ante review; FINMA kept the reference and wrote the distinction into the notes.

On the risk analysis, FINMA quotes the Federal Council’s dispatch on the AMLA revision: the organisational measures include a risk analysis, internal directives and, depending on the size and activity of the business, an IT-based system for screening relationships, originators and beneficiaries against sanctions. The risk analysis has to be repeated at regular intervals and may be integrated into the money laundering and terrorist financing risk analysis that Article 25(2) already requires the board or top executive body to approve.

Proportionality works through the existing tiers. FINMA states that the duty to comply with sanctions applies regardless of an intermediary’s activity, size or risk. The graduation sits in the tools: Article 20(2) ordinarily requires banks and securities firms to use an IT-based transaction-monitoring system, subject to the exception in Article 20(4) for banks and securities firms with few contracting parties and beneficial owners, or few transactions; FINMA can require one from the other categories where effective monitoring needs it (Article 20(5)), and Articles 75 and 75a give Title 5 intermediaries relief on running the AML unit under certain conditions. The VSV’s proposal for a new provision scaling the Embargo Act measures to activity and size, with relief for certain intermediaries, did not make it into the text.

Responsibilities stay where they were. SECO is the authority that controls enforcement of coercive measures under the Embargo Act; FINMA supervises the organisational requirements of financial market law. FINMA’s impact analysis states that Article 30 introduces no new duty and specifies an existing obligation of adequate risk management. For how the SECO and MROS reporting routes differ in a live case, see our note on the FINMA Russia sanctions notice of 20 August 2026.

Correspondent banking under Article 37: the deleted qualifier and direct-access accounts

Article 37 sits in Title 2, the special provisions for banks and securities firms, and governs correspondent banking relationships with foreign banks. The revision changes two paragraphs.

Paragraph 3 used to require the intermediary, in addition to the Article 15 investigations, to examine “depending on the circumstances” which AML and CFT controls the contracting party applies. The qualifier is deleted. FINMA says the phrase caused legal uncertainty, that correspondent banking relationships are as a rule relationships with increased risks, and that investigations therefore have to be assumed; their scope and depth follow the risk of the relationship under Article 6(1) AMLA. The SBVg read the deletion as having no material effect on existing practice. FINMA’s response describes the deletion as codifying lived practice and creating legal certainty, and it expanded the notes on the point.

Paragraph 5 is new. The intermediary may execute payments for clients of the contracting party who have direct access to the correspondent bank’s accounts only if it ensures that the contracting party has fulfilled its due diligence duties and sends it, on request, the documents relevant to those duties. These are payable-through accounts. The FATF’s 2016 mutual evaluation rated Switzerland’s implementation of criterion 13.2 as insufficient because such accounts were not explicitly prohibited, even though Swiss authorities had argued the practice did not exist in Switzerland and that point 4.4 of the ordinance’s annex treated it as an indicator of money laundering.

The final wording narrows the rule to direct access, after the SBVg warned that the draft could be read to cover every vostro account where the underlying originators of commercial payments are the respondent’s clients. A vostro relationship whose respondent clients have no direct access to the account falls outside paragraph 5; the general provisions of Article 37 continue to apply to it.

FINMA reads “documents” broadly, following the Federal Council’s 2019 dispatch on the AMLA: depending on the intermediary’s risk assessment, they can include details of individual transactions, the know-your-customer profile of the end clients, or other information that lets the correspondent bank investigate. The respondent, in turn, should have policies and processes to obtain them. FINMA presents the paragraph as its long-standing supervisory practice. Country-level FATF findings feed the same respondent file: our note on the FATF Türkiye mutual evaluation and the respondent file shows how technical-compliance findings are used in that review, and respondent country risk also shifts with each plenary, as our note on the FATF October 2026 plenary list updates sets out.

Title 5 intermediaries: doubts about the controlling person and sub-accounts

Article 56 sets the cascade Title 5 intermediaries use to establish the controlling person of an unlisted operating legal entity or partnership. Step one is a written declaration naming whoever holds, directly or indirectly, alone or in concert, at least 25 percent of the votes or capital. Step two, in paragraph 2, applies if the company is not controlled by those persons: a declaration on who controls it by other means. Step three falls back to the managing person.

The amended paragraph 2 adds a second trigger for step two: “or if there are doubts about it”. An intermediary that doubts whether the 25 percent holders really control the company now has to obtain the written declaration on control by other means. FINMA traces the change to the OECD Global Forum’s 2020 peer review of Switzerland on exchange of information on request, which found no requirement to look for other controlling persons in that situation, and to the FATF’s 2023 follow-up report, which made the same point under criterion 10.10. FINMA describes the text as matching its current interpretation of Article 56.

Article 65 deals with contracting parties that are themselves supervised financial intermediaries or tax-exempt occupational pension schemes. Paragraph 1 exempts them from the beneficial-owner declaration; paragraph 2 lists the cases in which the declaration is always required: suspicion of money laundering or terrorist financing, a FINMA warning about general abuses or about the specific contracting party, and domicile in a country whose institutions FINMA warns against generally. New letter (d) adds a fourth case: the contracting party keeps sub-accounts for individual clients. FINMA says this matches its practice under Article 4 AMLA and that such accounts carry risks that could otherwise hardly be controlled or limited.

Banks reach the same two points through VSB 27. Its Article 46 requires identification and the establishment of the controlling person or beneficial owner to be repeated when doubts arise that the bank’s own investigations cannot dispel, and its Article 33(2) requires a beneficial-owner declaration from foreign intermediaries that keep sub-accounts for individual clients.

VSB 27 and the SRO-SVV regulation: where the four-month transition sits

The ordinance refers to recognised self-regulation as a minimum standard. Article 35 now sends banks and securities firms to VSB 27 for identifying contracting parties and establishing controlling persons and beneficial owners, replacing the reference to VSB 20 of 13 June 2018. Articles 40(4) and 41(3) do the same for fund management companies and for managers of collective assets of foreign collective investment schemes. Article 42(1) sends insurers active in direct life insurance and mortgage lending to the SRO-SVV regulation of 23 October 2026, which replaces the regulation of 25 October 2022.

VSB 27 enters into force on 1 January 2027 (Article 67) with a transition period of four months from that date (Article 68). Its rules apply to business relationships opened after the transition expires and whenever due diligence is repeated under Article 46. Existing relationships do not need new forms, subject to Article 7 AMLA. The SRO-SVV regulation (Article 26) also allows four months; during that window the 2022 regulation still governs new relationships, the updating of documents under its Article 16(2) and repeated due diligence under its Article 12(1).

Those transitions belong to the self-regulation alone. The amending decree contains only an entry-into-force clause, so Articles 9b, 30, 37(3) and (5), 56(2) and 65(2)(d) apply from 1 January 2027. Reading the two layers together: a bank opening an entity relationship in February 2027 may still be inside the VSB 27 transition for its identification forms, while Article 9b and Article 37(5) already bind it.

The revised self-regulatory rules also address discrepancies between an intermediary’s beneficial-owner information and the Swiss transparency register, as discussed in the FAQ below. The register began ordinary operation on 1 October 2026. In November 2026 its official website stated that register queries and reports of discrepancies were not yet possible, that both were expected via the API no earlier than January 2027, and that the date for EasyGov access was still open. The VSB 27 and SRO-SVV discrepancy rules apply when an institution consults the register. The SRO-SVV regulation contains its own version of the Embargo Act measures in Article 22a, pointing to the AML unit, monitoring, new products, staff training and delegation.

The Liechtenstein repeal and the renumbered headings

Article 10(3) allowed certain domestic payment orders for goods and services to carry the reduced data set of paragraph 2 where full compliance with paragraph 1 was technically impossible. FINMA explains that payments to and from Liechtenstein were treated as domestic on that basis, although the FATF regards them as cross-border. Since the QR code was introduced in Swiss payment traffic on 1 July 2020, those payments have carried the full data set, so FINMA repeals the paragraph as obsolete.

The structural changes are formal, in FINMA’s words, but they move citations. Chapter 4 of Title 1 is renamed “Measures to combat money laundering and terrorist financing” and covers Articles 9a to 29. The former chapters 4 to 8 become sections 1 to 5: general due diligence, special due diligence, documentation and information of authorities, organisational measures, and involvement of third parties. A new chapter 5 holds Article 30 on Embargo Act measures. Directives that cite “Chapter 7 AMLO-FINMA” for organisational measures will point at what becomes section 4 of chapter 4.

Advisers under the revised AMLA: FINMA Guidance 06/2026 on Circular 2011/1

The revised AMLA extends its scope to specified advisory services, including certain activities connected with real-estate transactions and the formation or establishment of non-operating legal entities, subject to the applicable statutory and regulatory scope conditions. FINMA Guidance 06/2026 of 10 November 2026 states that Circular 2011/1 “Activity as a financial intermediary under the AMLA” (status 4 November 2020) needs revising and that FINMA will do so as soon as possible. Until then, the circular’s scope is limited to activities as a financial intermediary under Article 2(2) and (3) AMLA. It does not apply to adviser activities under Article 2(3bis) and (3ter) AMLA, and it says nothing about whether an activity that is not financial intermediation now falls under the AMLA as advice.

Margin numbers dealing with activities outside financial intermediation that now fall under the AMLA as advice do not apply where they contradict higher-ranking law; FINMA will delete or adapt them in the revision. The guidance names margin numbers 3, 60 and 96, and the blocks on insurance intermediaries (110 to 113), lawyers and notaries (114 to 123), financial intermediation in the real estate sector (124 to 132) and state action (133 to 141).

Supervision follows the intermediary. FINMA supervises the adviser activities of intermediaries it supervises directly, such as banks (Article 12a(1) AMLA). There is also an earlier notification deadline under the transitional provision of the amended Federal Council Anti-Money Laundering Ordinance (SR 955.01): FINMA-supervised institutions and FINMA licence holders that were acting as advisers on 1 October 2026 must notify FINMA by 1 December 2026, using the EHP form FINMA provides. Questions on adviser activities of intermediaries supervised by recognised supervisory organisations or SROs go to those bodies (Article 12a(2) and (3) AMLA). For advisers with no financial intermediary activity, FINMA has no competence; the recognised SROs provide support.

The ordinance stays silent on adviser duties by design. The SRO-SVV asked FINMA to set them out; FINMA replied that Article 17(1)(a) AMLA only lets it concretise the due diligence duties of intermediaries under Article 2(2)(a) to (dquater), while SROs concretise the duties of their affiliated persons, advisers included.

Requests FINMA declined, and what the revision leaves alone

Several consultation requests went nowhere, and they mark the edges of the revision. Two respondents wanted adverse media screening written into the ordinance. FINMA kept transaction monitoring principle-based and pointed to expectations it had already published: monitoring must be able to detect transactions to risk countries and deviations from the usual pattern of a relationship or from comparable relationships, should match the intermediary’s business, and has to combine static and dynamic criteria.

A call for stricter beneficial-ownership thresholds and a central register met the answer that Switzerland now has a transparency register under the Transparency Act and that the existing thresholds meet FATF standards. Requests to recognise verifiable credentials under the e-ID law, to set expectations on monitoring onboarding controls, and to define criteria for judging foreign counterparties’ AML regimes were all declared outside the scope of the revision.

The reporting provisions are also untouched. No article on reports to the Money Laundering Reporting Office Switzerland (MROS) appears in the decree; Article 25a, which assigns the decision on a report under Article 9 AMLA to executive management, keeps its current wording.

Frequently Asked Questions

Does Article 9b force a review of every existing entity relationship before 1 January 2027?

The decree sets no remediation deadline and no transitional rule; it simply applies from 1 January 2027. FINMA presents Article 9b as expressing a principle already applied in supervision, and the depth of investigation follows the risk of the relationship under Article 6(1) AMLA. Neither the decree nor the explanatory notes prescribe a look-back exercise, so the sequencing of existing files is left to the institution’s risk-based approach.

We are a portfolio manager. Does Article 30 oblige us to install an IT-based sanctions screening system?

Article 30 applies Article 20 by analogy. Article 20(2) establishes the general IT-based transaction-monitoring requirement for banks and securities firms, while Article 20(4) permits banks and securities firms with few contracting parties and beneficial owners, or few transactions, to dispense with an IT-based transaction-monitoring system. For a portfolio manager (Article 2(2)(abis) AMLA), the relevant paragraph is Article 20(5): FINMA may require an IT-based monitoring system where effective monitoring makes this necessary. FINMA states that the duty to comply with sanctions applies regardless of an intermediary’s activity, size or risk, while the dispatch it quotes ties IT-based screening to the size and activity of the business. FINMA expects the check to happen before the transaction.

Does Article 37(5) apply when the respondent belongs to our own banking group?

Yes, where the respondent’s clients have direct access to the correspondent’s accounts. FINMA’s notes state that Article 37 also covers banks of the same group and, in line with FATF Recommendation 13, contains no intra-group exception: the duties attach to the correspondent relationship. FINMA expects group membership to make the investigations and the exchange of documents easier in practice.

The transparency register shows a different beneficial owner from our file. Can the account still be used?

For banks, VSB 27 Article 45(2) provides that a discrepancy within the meaning of Article 30 of the Transparency Act, or a note in the register, does not prevent use of the account if there is no doubt about the bank’s own VSB-based data, and Article 46(4) says no repetition of due diligence is needed in that case. The SRO-SVV regulation has parallel rules for insurers. The ordinance contains nothing on the point: FINMA said the legality principle prevents it from issuing implementing rules on the register.

Do sanctions hits now go to MROS because Article 30 sits in the AML ordinance?

Article 30 governs organisational measures and creates no reporting channel. SECO remains the authority controlling enforcement of Embargo Act coercive measures, and the amending decree changes none of the ordinance’s provisions on reports under Article 9 AMLA. Whether a sanctions case also involves a suspicion that triggers an MROS report is a separate question under the AMLA.

Are asset blocks under the Foreign Illicit Assets Act covered by Article 30?

No. A respondent asked FINMA to mention the Foreign Illicit Assets Act (SRVG), noting that persons affected by SRVG blocks are not automatically listed in SECO’s SESAM database, which rests on the Embargo Act. FINMA replied that the legislative mandate for organisational measures covers the Embargo Act only, so Article 30 stays limited to it.

Related Articles

• FINMA Russia Sanctions: The 20 August 2026 Measures: Swiss implementation of the August 2026 Russia measures and the separate SECO and MROS reporting routes.
• FINMA Belarus Sanctions: The 19 September Crypto and Credit Bans: the digital rouble and Belarus crypto-provider bans and what they mean for Swiss screening.
• FINMA Circular 2016/7 Revision: e-ID, QR Codes and Liveness Checks: the November 2026 changes to online identification under Swiss AML rules.
• FATF Türkiye Mutual Evaluation 2026: Refreshing the Respondent File: how a mutual evaluation’s findings feed correspondent banking reviews.
• FATF October 2026 Plenary: Four Grey-List Exits, Black List Unchanged: the latest FATF list changes and how screening rules absorb them.

Key Takeaways

• Plan two go-live dates: 1 January 2027 for the amended ordinance articles, and the end of April 2027 (calculated) for VSB 27 and SRO-SVV forms and procedures.
• Entity KYC files need the control path to natural persons, recorded at a depth that rises with structural complexity.
• Sanctions directives, training and outsourcing follow the AML rulebook by analogy, with checks before execution.
• Correspondent banks: inventory any respondent arrangement giving end clients direct account access, intra-group ones included.
• Title 5 intermediaries: doubt about the 25 percent holders opens the “other means” step, and a counterparty keeping client sub-accounts always owes a beneficial-owner declaration.
• Internal policies citing AMLO-FINMA chapter numbers need re-referencing.
• Advisers: FINMA-supervised institutions and licence holders that were acting as advisers on 1 October 2026 notify FINMA by 1 December 2026 (EHP form); adviser questions for SRO-supervised intermediaries go to the SRO.

Sources and References

• FINMA press release, “FINMA publishes partially revised FINMA Anti-Money Laundering Ordinance” (10 November 2026): finma.ch
• FINMA, Geldwäschereiverordnung-FINMA, amending decree of 29 October 2026 (provisional version, German): FINMA PDF
• FINMA, partial revision of AMLO-FINMA, explanatory notes (Erläuterungen) of 29 October 2026: FINMA PDF
• FINMA, report on the results of the consultation of 12 May to 9 June 2026 (29 October 2026): FINMA PDF
• FINMA, consultation draft of the amending decree (12 May 2026): FINMA PDF
• FINMA press release on the consultation (12 May 2026): finma.ch
• FINMA Guidance 06/2026, explanations on FINMA Circular 2011/1 following the revision of higher-ranking law (10 November 2026): FINMA PDF
• Swiss Bankers Association, Agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence (VSB 27), valid from 1 January 2027 (FINMA copy): FINMA PDF
• SRO-SVV, regulation on combating money laundering and terrorist financing, in force from 1 January 2027 (FINMA copy): FINMA PDF
• Federal Office of Justice, “Federal Council brings new anti-money laundering rules into force” (12 June 2026): bj.admin.ch
• FINMA, “Hinweise zur Revision des Geldwäschereigesetzes (GwG) und der Geldwäschereiverordnung (GwV) per 1. Oktober 2026” (adviser notification by 1 December 2026, EHP form): finma.ch
• Swiss Transparency Register, “Wie kann man das Register abrufen?” (availability of register queries and reports of discrepancies): transpareg.admin.ch
• FINMA Anti-Money Laundering Ordinance (AMLO-FINMA), SR 955.033.0: Fedlex
• Anti-Money Laundering Act (AMLA), SR 955.0: Fedlex
• Embargo Act (EmbA), SR 946.231: Fedlex

Before 1 January 2027: the AMLO-FINMA files to update

The revision lands on five artifacts: the AML directives (Articles 9b and 30), the sanctions risk analysis and screening set-up (Article 30 with Articles 20 and 25(2)), entity KYC procedures and documentation (Article 9b, and Article 56(2) for Title 5), correspondent due diligence for direct-access arrangements (Article 37(5)), and the VSB 27 or SRO-SVV forms on the self-regulation timetable. Under Article 26(1), applied by analogy, the Embargo Act directives need the same approval by the board of directors or top executive body as the AML directives, and Article 30 applies from 1 January 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.