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Checklist: regularising a relationship inherited from the era of banking secrecy

  • Verify the tax compliance of the client’s assets in every country in which the client is or has been a taxpayer, and document the evidence obtained.
  • Identify any indicia of US tax status and apply the corresponding FATCA procedures.
  • Ensure that the information required under the automatic exchange of information is collected and transmitted correctly.
  • Examine the history of fund flows, in particular transfers to other institutions and large withdrawals in cash or precious metals.
  • Document the decision to maintain or terminate the relationship, together with the conditions under which the assets leave the institution.
  • Assess the residual criminal and reputational risks for the institution and for the staff concerned.

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 September 2025.

Setting up or expanding in Switzerland?

Helvetica Register is an information portal. It explains what companies and entrepreneurs from around the world, and in particular from Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, need to know about doing business in Switzerland: company law, commercial contracts, licences, banking, tax and residence.

Legal advice in Switzerland is provided by Ressos Legal, a Zurich law practice advising on all areas of Swiss law under the direction of Dr Alexander Ressos. Further information is available at www.ressos.ch.

Your project in Switzerland Speak to Dr Alexander Ressos Company formation, shareholder and commercial agreements, acquisitions, licences, bank accounts, tax and residence permits: I advise on Swiss law and coordinate with your lawyers in your home country, as well as local counsel in other jurisdictions as required.