The 2025 revision: lawyers, notaries and advisers

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For a long time the Anti-Money Laundering Act left outside its scope those advisory activities which involve no financial intermediation: the formation of companies, foundations and trusts, the provision of registered offices and directors, and advice on structuring. The offshore data-leak scandals had shown that such services, rendered by lawyers, notaries and fiduciaries, were being used to conceal assets, and the Financial Action Task Force had in any event reproached Switzerland for this gap. After a first attempt failed in 2021, Parliament adopted on 26 September 2025 a revision that subjects certain advisory activities to due diligence obligations, with adjustments designed to preserve the professional secrecy of lawyers.¹

For the Geneva financial centre, whose lawyers, notaries and fiduciaries form part of the cluster, this revision has practical consequences: identification of clients and beneficial owners for the activities concerned, documentation and, under certain conditions, the reporting of suspicions. This last obligation, which the legal profession experienced as an encroachment on its secrecy, has been circumscribed by the legislature. The drafting and advisory professions described in Part J are now, for a portion of their activities, intermediaries within the meaning of the fight against money laundering, which brings them closer to the banks and the asset managers.

Notes

Revision of the Anti-Money Laundering Act adopted by Parliament on 26 September 2025, cited in Part E; “Blanchiment d’argent en Suisse : nouvelles obligations du conseiller” (Money laundering in Switzerland: new obligations of the adviser), Croce & Associés, 20 October 2025. ↩

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.

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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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The 2025 revision: lawyers, notaries and advisers

Notes

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