The Swiss Federal Council has triggered a pivotal shift in its anti-money laundering architecture by launching a consultation on new ordinances defining how the country’s long-awaited transparency framework for legal entities will operate. The consultation, which runs until January 2026, sets the groundwork for a central beneficial ownership register and an expanded reach of the Anti-Money Laundering Act to capture consultancy activities long used as laundering conduits. This marks the country’s most significant AML modernization in more than a decade, reflecting growing international pressure to tighten its corporate secrecy rules.

Beneficial Ownership and the New AML Focus

The Transparency of Legal Entities and Identification of Beneficial Owners Act represents a fundamental break from Switzerland’s long-standing tradition of discretion in company ownership structures. It introduces a centralized register that will document and verify the individuals who ultimately control legal entities, closing loopholes that have historically enabled hidden ownership networks. The register will be managed by the Federal Department of Justice and Police, while an independent audit unit at the Federal Department of Finance will verify data accuracy and reliability.

Under this framework, companies must disclose detailed ownership and control information, including the chain of intermediaries, to ensure that the beneficial owner can be traced. This obligation extends beyond corporations to cover foundations, trusts with Swiss connections, and partnerships where opacity has historically facilitated illicit layering. For financial crime professionals, this reform directly addresses weaknesses repeatedly identified by international bodies concerning Switzerland’s beneficial ownership transparency.

The measure also enhances the monitoring powers of entities subject to the Anti-Money Laundering Act, such as banks, fiduciaries, and external asset managers, granting them streamlined access to verified ownership data. By improving data integrity and timeliness, Switzerland seeks to strengthen the detection of complex money flows that pass through its financial and corporate sectors. The move is designed to ensure that beneficial ownership information is not only recorded but kept current, preventing outdated or incomplete data from undermining investigations.

Expanding AMLA Coverage to Consultancy Services

The revised Anti-Money Laundering Act now explicitly covers consultancy services connected to the establishment, structuring, or financing of legal entities. These advisory segments have been among the most exploited channels for money laundering, particularly through real estate and cross-border investment vehicles. By bringing consultants, corporate service providers, and intermediaries under the same compliance umbrella as financial institutions, the revision dismantles a long-standing blind spot in the Swiss AML framework.

The new rules require consultants to conduct customer due diligence, verify the identity of clients and beneficial owners, and report suspicious transactions to competent authorities. This extension reflects the recognition that professional enablers, often positioned as facilitators rather than participants, play a decisive role in concealing ownership trails. The AMLA expansion not only aligns Switzerland with FATF recommendations but also sends a message that advisory professions will no longer enjoy immunity from oversight.

Furthermore, the revised Anti-Money Laundering Ordinance details the range of consultancy services covered and defines supervisory responsibilities. The text clarifies that firms engaged in advising on asset structuring or corporate domiciliation will face the same monitoring requirements as banks. By establishing unified reporting standards and enhancing inter-agency information sharing, the reform addresses fragmentation between financial intelligence units, supervisory authorities, and law enforcement.

Strengthening Supervision and Data Integrity

The upcoming ordinances introduce a data verification system under the authority of the Federal Department of Finance, marking a strategic move toward proactive supervision. Companies will need to ensure that beneficial ownership details are not only submitted but regularly updated to maintain compliance. Penalties for failure to report or for submitting inaccurate information are expected to include administrative fines and temporary restrictions from engaging in business activities.

Switzerland’s dual-agency oversight model is intended to strike a balance between enforcement and proportionality. While the justice department manages data collection and access, the finance department will oversee the auditing of information and ensure its consistency across registers. This structure is designed to prevent regulatory capture and enhance accountability.

Another major improvement is the simplification of inter-agency communication. The ordinances propose mechanisms allowing real-time exchange of beneficial ownership data among supervisory bodies, the financial intelligence unit, and prosecutors. This interoperability aims to prevent duplication of requests and enable early detection of discrepancies, a critical factor in identifying complex layering operations involving shell entities.

The reform also reflects a conscious alignment with FATF’s upcoming mutual evaluation. By embedding transparency and data accuracy at the heart of its AML strategy, Switzerland aims to strengthen its global reputation, counter persistent criticism of secrecy, and reinforce its compliance with international standards. The authorities have made it clear that implementation will be synchronized with FATF timelines to demonstrate tangible progress.

Transition Challenges and Future Outlook

The transition toward this transparency-based model will challenge a number of sectors. Corporate service providers and family offices, in particular, must now adapt to new verification duties, record-keeping obligations, and reporting standards. Many entities accustomed to confidentiality will face significant operational adjustments, from client communication to data governance and secure storage systems.

One expected hurdle is the reconciliation of beneficial ownership data across different registries and cantons. Given Switzerland’s decentralized structure, ensuring consistency between federal and cantonal data may prove complex. However, the centralized register aims to replace fragmented databases with a single, standardized platform.

Legal experts anticipate a phased rollout that will prioritize high-risk sectors such as real estate, fiduciary management, and corporate formation services. The ordinance-based approach offers flexibility to refine definitions and adapt supervision mechanisms over time. While implementation will be gradual, early engagement from regulated entities will be crucial to avoid last-minute compliance disruptions.

From a financial crime prevention standpoint, these measures are more than administrative. They represent an operational shift from reactive investigation to preventive transparency. Access to accurate ownership information allows financial institutions to better assess risk, identify ultimate beneficiaries, and escalate suspicious cases earlier in the transaction cycle. The new framework is expected to facilitate faster freezing of assets, particularly in cross-border money laundering and terrorist financing investigations.

By expanding the AML perimeter to include consultants, Switzerland is acknowledging that the laundering ecosystem extends far beyond banks. The integration of new actors into the AML framework will also enhance collaboration between compliance teams, tax authorities, and law enforcement. Such coordination is vital to prevent the misuse of Swiss corporate structures for concealing proceeds of crime, tax evasion, or politically exposed persons’ wealth.

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Related Links

• Federal Department of Finance – Anti-Money Laundering
• Federal Department of Justice and Police – Legal Entities Transparency
• Money Laundering Reporting Office Switzerland
• Financial Action Task Force – Switzerland Mutual Evaluations
• Swiss Federal Council Official Communications

Other FinCrime Central Articles About Beneficial Ownership

• Canada Tightens Beneficial Ownership Rules to Combat Dirty Money
• The Shell Company Mirage: Why Beneficial Ownership Registries Fail By Design
• FinCEN’s 2025 Agenda Blends BSA Modernization, Beneficial Ownership and Digital Assets

Source: Swiss Federal Authorities

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