Anti-Money Laundering: AMLA, CDB and Beneficial Ownership — conclusion

Conclusion

The Swiss anti-money laundering regime was built in response to scandals. The Chiasso affair of 1977 led to the first agreement on due diligence of the banks. The assets of Marcos, Duvalier, Abacha and other rulers led to the policy of freezing and restituting illicit assets, while the Lebanon Connection of 1988 led to the criminal offence of money laundering in 1990. The Anti-Money Laundering Act of 1997 imposed on financial intermediaries duties of identification, clarification, documentation, organisation and reporting to MROS, supervised by FINMA and by self-regulatory organisations. The CDB of the Swiss Bankers Association specifies the identification of beneficial owners through its forms. Since 2016, aggravated tax misdemeanours have been predicate offences of money laundering, which connects the regime with the end of banking secrecy for tax purposes.

The Foreign Illicit Assets Act of 2016 codified the Swiss practice of freezing and restituting the assets of foreign politically exposed persons, with the support of the Basel Institute on Governance in asset recovery worldwide. Mutual legal assistance and the cooperation of financial intelligence units connect the Swiss regime with those of other countries. Since 2022, Switzerland has applied the sanctions of the European Union against Russia, which has made sanctions compliance a central concern of the financial centre. The Act on the Transparency of Legal Entities of 2025 creates a federal register of beneficial owners and extends due diligence duties to certain advisers. Through the Basel AML Index and its International Centre for Asset Recovery, the Basel Institute on Governance gives the city a voice in the global debate on financial integrity, while the Wolfsberg standards show how much of the regime is shaped by private actors. The extension of the regime to dealers, advisers and providers of crypto-asset services, together with the practical burden of de-risking, shows that the fight against money laundering now reaches far beyond the banks. The next chapter examines the end of banking secrecy for foreign tax purposes.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Anti-Money Laundering: AMLA, CDB and Beneficial Ownership — conclusion

Conclusion

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