Scenario 2: Automated compliance

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In the second scenario, the greatest change occurs in compliance and supervision. By 2035, the monitoring of transactions, the onboarding of clients and the screening against sanctions lists are largely automated. Banks share data through privacy-preserving techniques of the kind tested in Project Aurora, so that networks of suspicious transactions can be detected across institutions and borders.¹ Supervisors no longer review samples of files. They supervise the models that institutions use and receive data in real time, so that supervision itself becomes partly automated.

This scenario would change the work of compliance departments and of the advisers who assist them. The number of routine analysts would fall, while the demand for specialists in model validation, data governance and the legal assessment of complex cases would rise. Clients would experience faster onboarding but also more systematic scrutiny, because automated systems would detect inconsistencies that human reviewers might have missed. For clients with complex structures, such as trusts and foundations or holdings of crypto-assets and digital assets, the documentation of the origin of wealth would become even more important. Indicators of this scenario would be legislative changes that permit data sharing between financial intermediaries, supervisory projects on real-time reporting and the spread of shared utilities for client due diligence.²

Notes

Scenario constructed by the author, building on BIS Innovation Hub, Project Aurora (2023). On the legal framework for information sharing between financial intermediaries under the revised AMLA, see Part E, Chapter III. Status to be verified. ↩
On shared know-your-customer utilities and regulatory reporting projects, see the work of the BIS Innovation Hub and of national supervisors on suptech and regtech. Status to be verified. ↩

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.

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Scenario 2: Automated compliance

Notes

Setting up or expanding in Switzerland?