Switzerland
Overview
Switzerland’s AML framework is based on the Anti-Money Laundering Act of 1997 as amended, implementing ordinances and criminal-law provisions. The revised AMLA, the new federal transparency-register framework and their associated ordinances entered into force on 1 October 2026, subject to the stated exception for provisions concerning state notaries.
AMLA duties require identification of contracting parties and beneficial owners. From 1 October 2026, the new federal transparency-register framework and related revised AMLA duties are in force, with statutory transition periods applying to registration of affected legal entities.
Suspicious business relationships meeting the statutory threshold are reported to MROS. FINMA ordinances, guidance, SRO rules and case law shape operational due diligence and reporting practice.
Compliance Calendar2
Requirement
Suspicious activity report to MROS
Authority / Report toMoney Laundering Reporting Office Switzerland (MROS)
Deadline / triggerImmediately (unverzüglich).
Requirement
- Subject scope
- Financial intermediaries and traders subject to the Swiss Anti-Money Laundering Act (AMLA), within Article 9 scope.
- Trigger
- Knowledge or reasonable grounds to suspect the statutory Article 9 circumstances.
- Filing channel
- MROS requires STRs, attachments and additional information to be transmitted through goAML.
Impact
- Consequences of non-compliance
- Non-compliance may lead to criminal, regulatory or supervisory consequences depending on the breached AMLA duty and supervised status.
- Enforcement authority
- MROS / fedpol receives reports; FINMA, SROs and other competent authorities enforce relevant compliance duties.
- Operational impact
- Maintain goAML readiness and escalation procedures so Article 9 reports can be filed immediately.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money TransferSecurities / InvestmentInsurance
Money-laundering risk analysis and risk-based controls
Authority / Report toSwiss Financial Market Supervisory Authority (FINMA)
Deadline / triggerOngoing; maintain a documented risk analysis as a central strategic risk-management instrument. No universal external filing date is asserted.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money TransferSecurities / InvestmentInsurance
- Subject scope
- FINMA-supervised institutions subject to the Anti-Money Laundering Ordinance-FINMA and related supervisory requirements.
- Trigger
- Continuous exposure to ML/TF risks and changes in business model, customers, products, markets and controls.
Impact
- Consequences of non-compliance
- Deficiencies may trigger FINMA supervisory/enforcement measures; consequences depend on the facts and breached rule.
- Enforcement authority
- FINMA
- Operational impact
- Use the risk analysis to steer customer risk classification, controls, monitoring, resources and management reporting.
Authorities & FIU5
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline47
On 14 October 2026 the Swiss Federal Council presented the third national ML/TF risk assessment prepared by the CGMF. Overall exposure remained stable; organised crime, corruption and property and tax crime were highlighted. The report recommends strengthening supervisory resources, information exchange and evidence, and evaluating reporting, precious-metals controls and the new transparency register.
SECO announced on 13 October 2026 that EAER had revised the authorisation form for money transfers under Article 21 of the Ordinance on Measures against the Islamic Republic of Iran. Effective immediately, SECO will accept only the updated form. The notice is an administrative sanctions-processing change, not evidence of a newly imposed ban or changed sanctions listing.
On 8 October 2026 FINMA adopted a partial revision of Circular 2016/7 “Video and online identification”, which sets FINMA practice for AMLA due-diligence obligations when onboarding clients through digital channels. The revised framework permits use of the Swiss e-ID for identification, treats identification documents bearing a QR code as equivalent to MRZ documents for the relevant process, introduces liveness detection as an additional security measure for online identification and permits reliable digital processes for verifying place of residence. FINMA states that the changes enter into force on 1 November 2026.
On 25 September 2026, the Swiss Federal Council harmonised and clarified financial provisions in four sanctions ordinances implementing UN sanctions concerning terrorism financing and proliferation financing: the DPRK, Iran, ISIL (Da’esh)/Al-Qaeda and Taliban regimes. It also extended specified Iran-ordinance exemptions from reporting and authorisation requirements for money transfers to international organisations.
On 9 September 2026, the Swiss Federal Council adopted additional Sudan sanctions prohibiting the purchase, import and transit of gold originating in Sudan, related services and financial assistance, and the sale or supply to Sudan of specified chemicals used in gold mining and extraction. The measures entered into force on 10 September 2026.
On 14 August 2026, Swiss federal authorities announced the National Risk Assessment (NRA): Legal Entities and Legal Arrangements, prepared by the Interdepartmental Coordinating Group on Combating Money Laundering and the Financing of Terrorism (CGMF). The assessment identifies heightened money-laundering risks involving foreign legal entities and complex legal structures. The Federal Council was informed of its findings on 12 August 2026. This is publication of an official national risk assessment, not a change to statutory duties.
The Federal Council fixed the commencement date and transition to the new beneficial-owner transparency register and revised AML framework.
The Swiss Federal Council decision published on 12 June 2026 set 1 October 2026 as the commencement date for the revised Anti-Money Laundering Act, the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners, and associated ordinances (subject to the stated exception for provisions concerning state notaries). That legal commencement date has now been reached.
Parliament completed the legislative reform creating the transparency-register architecture and revised AML duties for higher-risk activities.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The AMLA revision adopted in 2021 became effective in January 2023, strengthening due-diligence and related preventive requirements.
FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Swiss Parliament adopted amendments to the Anti-Money Laundering Act strengthening parts of the AML framework.
FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FINMA adopted a revised Anti-Money Laundering Ordinance implementing updated due-diligence and organisational requirements.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Egmont Group's official Member FIU Information register records Switzerland's FIU admission date as 1998-04-01.
The Money Laundering Reporting Office Switzerland was set up in April 1998 as the central reporting office/FIU under the new AMLA architecture. This institutional milestone is separated from the statute’s 1997 adoption.
Parliament adopted the dedicated federal Anti-Money Laundering Act on 10 October 1997. The law did not become operative on the adoption date; its 1998 entry into force is recorded separately.
The AMLA adopted in 1997 entered into force in 1998, creating the dedicated federal preventive AML framework. The Timeline now separates parliamentary adoption from legal effectiveness.
FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF records Switzerland as a member since 1990.
Switzerland introduced the criminal offence of money laundering in 1990, creating a criminal-law foundation before the dedicated federal preventive AML statute.
The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗