Switzerland Tightens Its Anti-Money Laundering Framework: What the 2026 Reform Means

Switzerland’s reputation as a financial centre rests, in part, on its credibility as a jurisdiction that takes the integrity of its financial system seriously. That credibility requires active maintenance. On 26 September 2025, the Swiss Federal Chambers adopted two significant pieces of legislation: the Federal Act on the Transparency of Legal Entities (LETA) and a partial revision of the Anti-Money Laundering Act (AML). Together, they represent the most substantial update to Switzerland’s AML framework in recent years.

The reforms are expected to enter into force in the second half of 2026. They will affect legal entities incorporated in Switzerland, the advisers who help create or structure them, and the professionals involved in Swiss real estate transactions. For foreign individuals with Swiss holdings or property, understanding what is changing matters now; the preparatory steps begin before the law takes effect.

Two Laws, One Reform

The September 2025 legislation has two distinct components, each with its own scope. The LETA addresses transparency: it introduces obligations for legal entities, such as companies limited by shares (SA) and limited liability companies (Sàrl), to register their beneficial owners in a new federal register. All entities within the scope of the legislation must collect, verify and keep up to date information relating to their beneficial owners. The revised AML addresses supervision: it extends the reach of AML obligations to categories of advisers who were previously outside the regulated perimeter. Both laws are designed to bring Switzerland further into line with the standards set by the Financial Action Task Force (FATF).

The Transparency Register: Who Is the Beneficial Owner?

The LETA introduces new transparency obligations for legal entities and provides for the establishment of a central federal register of beneficial owners (the Transparency Register). The register will enable the competent authorities to access reliable information on the beneficial owners of a legal entity quickly and efficiently. It will be administered by the Federal Department of Justice and Police. A supervisory authority attached to the Federal Department of Finance will verify the accuracy, completeness and currency of the information.

Access to the register will not be public. It will be restricted to the relevant authorities and to persons subject to the Anti-Money Laundering Act (AMLA); this group includes financial intermediaries and, under the revised law, certain categories of advisers. For foreign families who hold Swiss assets through a company structure, the practical consequence is clear: the beneficial ownership chain will need to be documented and disclosed to the Swiss register.

Extended AML Obligations for Advisers

The revised AML extends the scope of Swiss anti-money laundering regulation to certain advisory activities that previously fell outside the regulated perimeter. The legislation specifically targets advisory services provided in connection with real estate transactions and with the creation or structuring of legal entities. Lawyers, notaries, fiduciaries and other professionals who carry out these activities may become subject to AML due diligence obligations in circumstances where they were previously outside the scope of the regime.

This is a significant shift. Swiss lawyers advising on company formation, or notaries handling property transactions, will need to apply client due diligence procedures, identify beneficial owners, and in certain circumstances report suspicions of money laundering to the relevant authority. The practical burden falls primarily on the professional; the client’s experience is that their adviser will ask more structured questions about ownership and the source of funds than they may have done previously.

What This Means for Real Estate Transactions

Swiss property transactions have historically been handled by notaries who were not formally regulated under the AML. The revised law changes that for transactions where advisory services are provided. Buyers and sellers working with a Swiss lawyer or adviser on a property acquisition or disposal can expect due diligence requirements to become more formalised. Requests for documentation on the source of funds, the identity of beneficial owners, and the structure of any holding vehicle are likely to become standard where they were not always so. This does not add substantial cost or delay for straightforward transactions; it does require that the relevant documentation is prepared and ready.

What This Means for Company Formation and Structuring

For international families using Swiss holding companies, Sàrls, or other legal vehicles to hold assets, the combined effect of the LETA and the revised AML is twofold. First, the beneficial ownership information for those structures will need to be registered and maintained accurately in the new federal register. Second, the advisers who assist in creating or restructuring those entities will themselves be subject to AML obligations during the engagement. Structures that have not been reviewed recently may require attention to ensure that the beneficial ownership information on file is current and that the structure is appropriately documented before the new obligations take effect.

The Broader Context: FATF and Switzerland’s Evolving Standards

Switzerland has participated in FATF mutual evaluation processes for several decades. The 2016 FATF mutual evaluation identified areas for improvement in Switzerland’s anti-money laundering framework, and the 2021 revision of the Anti-Money Laundering Act (AMLA) formed part of Switzerland’s response to those findings. The 2025 legislative package builds further on that trajectory and is intended in particular to strengthen Switzerland’s alignment with FATF Recommendation 24 on transparency and beneficial ownership of legal persons.

Further details of the reforms, including links to the adopted legislative texts, are published by the State Secretariat for International Finance (SIF) and are available on the SIF website. The implementing ordinances were opened for consultation in October 2025 and are expected to be finalised before the legislation enters into force.

For Switzerland, the reforms serve a dual purpose. They address international pressure to improve transparency; they also reinforce the domestic case that the Swiss financial centre is a well-regulated, reputable environment. Both objectives are consistent with Switzerland’s long-term interest in maintaining the trust of foreign investors and international counterparts.

Frequently Asked Questions

Does the transparency register apply to all Swiss companies?

Capital companies, such as companies limited by shares (SA) and limited liability companies (Sàrl), are principally subject to this obligation. Cooperatives are also within the scope of the LETA. Foundations, associations, listed companies, sole proprietorships and certain other legal entities are not required to register in the Transparency Register.

Who will be able to access the beneficial ownership register?

The register will not be publicly accessible. Access will be limited to competent Swiss authorities and to persons subject to the Anti-Money Laundering Act (AMLA) for the purposes of complying with their statutory due diligence obligations. This includes financial intermediaries and, under the revised regime, certain categories of persons carrying out activities subject to AML requirements.

Will Swiss lawyers be required to report client information to authorities?

The revised AML introduces reporting and due diligence obligations for certain advisory activities. At the same time, Swiss professional secrecy rules continue to apply, and their interaction with the new AML obligations will require careful interpretation in practice. While the legislation preserves professional secrecy protections, the precise boundaries of lawyers’ reporting and compliance obligations are expected to become clearer through the implementing regulations and subsequent practice.

When do the new rules take effect?

Both the LETA and the revised AML are currently expected to enter into force in the second half of 2026. The implementing ordinances were opened for consultation in October 2025. The exact date has not yet been confirmed.

Should existing Swiss company structures be reviewed before the law comes into force?

Structures with complex beneficial ownership arrangements, or structures whose ownership documentation has not been reviewed recently, may benefit from assessing their current position before the new registration obligations take effect. Identifying and addressing gaps in advance is generally more efficient than responding to compliance issues once the register becomes operational.

Switzerland’s AML reform is not intended to prohibit legitimate ownership structures; rather, it introduces additional transparency and documentation requirements in line with evolving international standards. For international clients with Swiss holdings, the principal practical impact is likely to be an increase in the information and documentation expected by regulators and regulated intermediaries. Structures that are properly documented and maintained are likely to adapt more readily to the new framework, whereas structures that have not been reviewed recently may benefit from being assessed before the legislation enters into force.

Disclaimer: This article is for informational purposes only and does not constitute legal or tax advice. Readers should not act on the basis of this content without first seeking professional advice specific to their circumstances. For guidance tailored to your situation, please contact David Kohler. Learn more about his practice here.