The Swiss Financial Market Supervisory Authority (FINMA), the country’s financial markets regulator, has finalised a partial revision of its Anti-Money Laundering Ordinance, setting a 1 January 2027 deadline for firms to align with stricter due diligence expectations ahead of an upcoming international assessment.
The updated AMLO-FINMA reflects recent changes to both the Anti-Money Laundering Act (AMLA) and the Federal Council’s own Anti-Money Laundering Ordinance (AMLO). These changes were made with the forthcoming FATF mutual evaluation of Switzerland in mind. The final text follows a public consultation that FINMA ran earlier this year.
Alongside the ordinance, FINMA’s Board of Directors has approved two pieces of industry self-regulation as minimum standards. These are the revised agreement governing Swiss banks’ code of conduct on due diligence, which was updated for the same reasons, and the revised rules of the Self-Regulatory Organisation of the Swiss Insurance (SRO-SVV). Both take effect on the same date as the ordinance, and each grants firms a four-month transition period.
Feedback from the consultation led to several changes. FINMA amended the rules on correspondent banking with foreign banks to make clear that Article 37 para. 5 AMLO-FINMA covers only clients who can access the correspondent bank’s accounts directly. The regulator also expanded its explanatory notes in two areas. The guidance on transparency of ownership and control structures now sets out how this provision works together with the rules on complex structures and domiciliary companies, and explains the risk-based approach and the records firms must keep. Separately, the notes on new measures to stop breaches of coercive measures under the Embargo Act now give more detail on how the rules for monitoring business relationships and transactions apply by analogy.
Because the revised AMLA now extends to certain advisory services, FINMA also needs to update Circular 2011/1 on acting as a financial intermediary under the AMLA. To address this, the regulator has released standalone guidance. The guidance defines the Circular’s scope and clarifies which bodies are responsible for supervising advisory activities.
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Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
