On 10 November 2026, the Swiss Financial Market Supervisory Authority (FINMA) published the final version of the partial revision of its Anti-Money Laundering Ordinance (AMLO-FINMA). The text enters into force on 1 January 2027. In the same press release, FINMA announced that it has recognised as minimum standards the banks' revised agreement on their due diligence obligations and the revised regulations of the insurers' self-regulatory organisation. The aim: to adapt the fight against money laundering in Switzerland to the revised law and to the upcoming evaluation by the Financial Action Task Force (FATF).

What FINMA published on 10 November 2026

According to FINMA's press release of 10 November 2026, the authority took three separate decisions, each with a different scope.

  • The revised AMLO-FINMA. This is an act of FINMA itself. It sets out the due diligence obligations of the financial intermediaries it supervises. It enters into force on 1 January 2027.
  • Two self-regulatory texts recognised. FINMA's Board of Directors recognised as minimum standards the revised version of the agreement on the Swiss banks' code of conduct with regard to the exercise of due diligence (published by FINMA under its German name "VSB 27") and the revised regulations of the self-regulatory organisation of the Swiss Insurance Association (SRO-SVV). Both apply from 1 January 2027, each with a transitional period of four months.
  • A guide on Circular 2011/1. This circular defines who acts as a financial intermediary within the meaning of the Anti-Money Laundering Act (AMLA). The guide clarifies its scope and allocates supervisory responsibilities for advisory activities.

This is therefore an adopted text, not a draft. FINMA had opened the consultation on 12 May 2026 and closed it on 9 June 2026.

Which due diligence obligations are changing

The press release opening the consultation, published by FINMA on 12 May 2026, set out four areas of work. The final text largely takes them over.

  • Ownership and control structure. The financial intermediary must be able to understand who owns and who controls its contracting party.
  • Embargoes. The ordinance specifies the measures to be taken to prevent any breach of the coercive measures provided for by the Embargo Act.
  • Correspondent banks. For payable-through accounts, a payment for the clients of a correspondent bank is only permitted if that bank guarantees to provide, on request, all the necessary information on those clients.
  • Sub-accounts. The May draft provided for a declaration on the beneficial owner when a contracting party manages sub-accounts for certain clients. The press release of 10 November 2026 does not return to this point.

According to FINMA, the revision also codifies, on specific points, its supervisory practice already in force. Some of the rules therefore create no new requirement: they write into the ordinance what the authority already expected.

What the consultation changed

FINMA says it received numerous requests for clarification; some of them have been taken up in the explanatory notes. The press release cites one amendment to the text of the ordinance: Article 37 paragraph 5, on correspondent banking relationships with foreign banks. It specifies that the rule concerns clients who have direct access to the correspondent bank's accounts.

The other comments fed into the explanatory notes accompanying the ordinance. On the transparency of ownership and control structures, FINMA clarifies the link with the rules on complex structures and domiciliary companies. It also clarifies the risk-based approach and the documentation requirements. On embargoes, it details how to apply by analogy the rule on monitoring business relationships and transactions.

The report on the results of the consultation, the explanatory notes and the amending act, in a provisional version, are published in German and French. The opinions received are only available in German.

Why now: the revised AMLA and the FATF

The revision stems from a broader federal reform. On 26 September 2025, the Federal Assembly adopted the Federal Act on the Transparency of Legal Entities (TLEA) and a revision of the AMLA, the Federal Council recalled in its press release of 15 October 2025. The AMLA now extends to certain advisory activities, for example in real estate transactions or in the formation and structuring of legal entities. Hence FINMA's guide on Circular 2011/1.

The TLEA entered into force on 1 October 2026, according to the Federal Office of Justice (FOJ). The transparency register, which records the beneficial owners of legal entities, went live the same day. Some 2,500 volunteer companies had tested it during the pilot phase. The Federal Council aimed for entry into force in 2026 so that the FATF could take these measures into account in its next mutual evaluation of Switzerland. FINMA cites the same timetable for its ordinance.

What this changes for a bank customer or an SME

For an individual, the press release of 10 November 2026 announces no new document to provide when opening an account. Remote identification falls under another text: FINMA has revised its circular on online identification, in force since 1 November 2026, which notably accepts the e-ID.

For an SME, on our reading of the texts, the most direct effect concerns the bank's questions about the company's shareholders and control. The ordinance requires an understanding of the ownership and control structure, with a risk-based approach and documentation. A simple company owned by its founder should barely notice it. A holding company, a chain of companies or a domiciliary company should expect to document more.

This work relies on the transparency register. According to the FOJ, every legal entity subject to it must report its beneficial owners there, within a period of one month to two years depending on its legal form. Reporting is done via the EasyGov.swiss platform and is free of charge. The register is open to the authorities, financial intermediaries and advisers, for their obligations under the AMLA.

Again on our reading, two types of company are more directly targeted. First, those that manage sub-accounts for third parties, if the rule in the May draft has been retained. The rule on correspondent banks, for its part, targets the relationship between a Swiss financial intermediary and a foreign bank, and only clients who have direct access to that bank's accounts: an SME that simply makes international payments is not targeted as such. Second, those whose business involves countries under embargo: their bank must monitor relationships and transactions to avoid any breach of the coercive measures.

The oversight is not theoretical. On 29 September 2026, FINMA concluded proceedings against Julius Bär, an institution specialising in private banking. Among other things, it criticised the bank for failing to adequately verify the origin of the assets of clients linked to two Russian politically exposed persons. Other supervisory cases are gathered in the banks and FINMA section.

The texts and their timetable

TextAuthorConcernsIn force
TLEA and transparency registerParliament, FOJLegal entities subject to it1 October 2026
Revised Circular 2016/7 (online identification)FINMAIntermediaries that identify remotely1 November 2026
Revised AMLO-FINMAFINMAFinancial intermediaries supervised by FINMA1 January 2027
Revised banks' due diligence agreementBanking self-regulationBanks1 January 2027, four-month transition
Revised regulations of the insurers' self-regulatory organisationSwiss Insurance AssociationMembers of this organisation1 January 2027, four-month transition

What we do not yet know

  • The details of the revised banking agreement: FINMA publishes it in German and its press release does not list its changes.
  • The date of the FATF's mutual evaluation of Switzerland: FINMA and the Federal Council describe it as upcoming, without giving a date.
  • The official version of the ordinance: for now, FINMA only publishes a provisional version of the amending act.

Sources