Swiss Federal Council Announces New Anti-Money Laundering Rules Effective October 2026
The Swiss Federal Council has announced that several pieces of legislation aimed at strengthening measures to combat money laundering and terrorist financing will enter into force on October 1, 2026. This includes the revised Anti-Money Laundering Act (AMLA) and the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (LETA).
Introduction of the Transparency Register
The LETA introduces a central federal register of beneficial owners, maintained by the Federal Office of Justice. This register will contain information on individuals who ultimately control a legal entity, defined as those holding at least 25% of its capital or voting rights, or exercising control by other means. If no such person can be identified, the most senior member of the governing body must be reported.
The reporting obligations will apply to most Swiss companies and certain foreign legal entities with significant connections to Switzerland, such as ownership of Swiss real estate, a Swiss branch, or effective administration within the country. Swiss associations and foundations are generally excluded, except in specific cases where they control an entity subject to the LETA.
Extension of AMLA Due Diligence Obligations
The revision of the AMLA extends due diligence obligations to certain advisory activities considered to present higher money-laundering risks, including legal-entity structuring and certain real-estate transactions.
This extension may affect lawyers, notaries, independent legal advisers, accountants, real-estate brokers, and other professionals when they act in covered advisory roles. The new regime does not subject all legal or notarial services to AMLA obligations; its application depends on the nature of the activity, its connection with a covered transaction, and whether the activity is conducted professionally.
Quantitative thresholds have been introduced to define when advisory activities qualify as professional and therefore fall within scope. These include thresholds based on annual gross revenue, number of clients or transactions, assets concerned, and transaction volume.
Existing advisers falling within the new regime will have a short transitional period to apply for affiliation with a self-regulatory organization. However, the substantive AML due diligence obligations will apply from the entry into force of the revised AMLA. The application of the new rules to state notaries has been postponed to allow cantons to adapt their legislation.
Conclusion
From October 1, 2026, in-scope legal entities will face enhanced identification, verification, reporting, and record-keeping duties regarding beneficial ownership under the LETA. Financial intermediaries and certain advisers will also be subject to extended AML due diligence obligations and, where applicable, discrepancy-reporting duties.
Entities and professionals potentially affected by the new regime should use the remaining time to assess whether they fall within scope, identify their beneficial owners under the new criteria, document ownership and control structures, update internal processes, and prepare for registration and ongoing reporting obligations.
Early preparation will be key to limiting legal, operational, and reputational risks.
For further information on the impact of the LETA or the revised AMLA on your structure or activities, please contact the Federal Office of Justice or your legal adviser.