The transparency register and the identification of beneficial owners

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The Federal Act on the Transparency of Legal Entities, whose register comes into force on 1 October 2026, complements the fight against money laundering with a federal, non-public register of the beneficial owners of Swiss companies and other legal entities. This register is accessible to the authorities and, under certain conditions, to financial intermediaries.¹ Foundations and associations were exempted from registration at the close of the parliamentary debates, a point that Part F noted with regard to philanthropy.²

The register changes the work of compliance. The identification of the beneficial owner, required since the Due Diligence Agreement of 1977 and based on the client’s declaration, can now be checked against an official source. Discrepancies between the declaration and the register will have to be reported and resolved, and companies whose beneficial owners cannot be identified will lose their access to financial services. For Geneva, where tens of thousands of companies are held by foreigners through structures that are at times complex, implementation will require considerable work in 2026 and 2027. Fiduciaries and lawyers will bear a significant share of it.

Notes

Loi fédérale sur la transparence des personnes morales (LTPM) (Federal Act on the Transparency of Legal Entities), adopted on 26 September 2025, with the register entering into force on 1 October 2026, cited in Part E; PwC Switzerland, “Registre suisse de transparence” (Swiss transparency register), January 2026; Bonnard Lawson, newsletter of June 2026. ↩
“Les fondations et associations suisses sont définitivement dispensées de s’inscrire dans un registre de transparence” (Swiss foundations and associations are definitively exempted from registration in a transparency register), cited in Part F. ↩

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 transparency register and the identification of beneficial owners

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