Switzerland’s sweeping 2025 reform of its anti-money laundering (AML) regime has introduced significant changes that are transforming compliance expectations for financial institutions.
According to Moody’s, this “New Deal” demands that banks and other firms reassess their data frameworks and control systems to meet the enhanced scrutiny introduced by international bodies and domestic authorities. The Financial Action Task Force (FATF) identified critical gaps in due diligence (R.22, R.23, R.35), particularly around professional enablers and the application of effective and proportionate sanctions for AML and counter-financing of terrorism (CFT) violations.
The regulatory shift follows the Swiss Parliament’s adoption of a revised Anti-Money Laundering Act (AMLA) and the enactment of the Federal Act focused on tax transparency and the exchange of financial information. These changes align Switzerland more closely with FATF and EU standards, requiring institutions not only to document compliance but also to demonstrate operational effectiveness in their controls. Regulatory inspections and audits will increasingly focus on the adequacy of measures in practice, not just on paper.
The introduction of the central Ultimate Beneficial Ownership (UBO) register is one of the most notable changes, impacting more than 600,000 legal entities. With over CHF 100m in fines already issued in 2025, enforcement is intensifying. Article 697j of the Swiss Code of Obligations and Article 2a of AMLA are reshaping transparency standards by making beneficial ownership information more accessible, which is essential for cross-border investigations.
Major financial institutions have come under fire for gaps in AML screening and delays in reporting suspicious activity to the Money Laundering Reporting Office Switzerland (MROS). Failures in entity verification, beneficial ownership transparency, and inadequate trigger mechanisms for due diligence have exposed operational weaknesses. The increasing emphasis on cross-border data sharing, exemplified by participation in the FIU.net network, reflects a regional push toward unified financial crime intelligence.
The consequences of compliance failure are becoming increasingly personal. Under Article 29 of AMLA and FINMA Circular 2017/1, senior managers and compliance officers can now be held individually liable. Enforcement proceedings, and in some cases criminal prosecution, are being used to ensure greater accountability for internal control deficiencies and governance lapses.
The risk landscape is also evolving with digital assets, stricter sanctions regimes, and growing expectations from customers around data security and privacy. Financial institutions are now expected to offer robust asset protection, transparent risk disclosures, and ethical AI governance. This includes compliance with evolving standards targeting crypto providers, who must monitor wallet activity, verify ownership, and follow “travel rule” requirements for fund transfers above CHF 10,000.
To meet these challenges, banks are aligning with FINMA’s Guidance 08/2024, which outlines AI governance principles, alongside operational risk and cloud security frameworks laid out in Circulars 2018/3 and 2023/1. This signals a broader transformation as firms invest in secure, AI-enabled compliance infrastructures.
Modernising data architecture and adopting AI-based tools are becoming essential pillars of compliance. Scalable data platforms support real-time analytics and integrate risk intelligence across business units. AI solutions also enhance the screening of politically exposed persons (PEPs), sanctions monitoring, and media checks by improving accuracy and reducing false positives.
In parallel, new tools for entity verification and UBO identification allow institutions to automate due diligence by cross-referencing multiple data sources. This helps meet stringent Swiss transparency rules and streamlines beneficial ownership reporting.
A dynamic control environment is also crucial. Institutions are encouraged to adopt perpetual KYC (pKYC) models, implement event-driven risk triggers, and ensure audit readiness through robust documentation and regular control reviews.
In helping institutions adapt, Moody’s has formed a strategic partnership with Elliptic to offer advanced tools that support compliance transformation. By combining blockchain analytics with traditional financial intelligence, the alliance helps firms modernise control frameworks, conduct VASP due diligence, and mitigate regulatory risk as financial crime threats evolve.
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