Case typologies and a practitioner's checklist
How to read the typologies
The following typologies are anonymized composites. They are drawn from the cases described in this chapter, from the sectors listed by the MROS and from the risk factors identified in the national risk assessment. They do not describe any real client or institution. Each typology names the warning signs and the legal provisions that apply. Their purpose is to help relationship managers, compliance officers, fiduciaries and lawyers in Lugano to recognize patterns that recur in Ticino cases.
Typology 1: the inherited domiciliary company
A Lugano bank holds an account opened in 1998 for a company registered in a Caribbean jurisdiction. The beneficial owner named in the declaration was an Italian entrepreneur from Calabria who died in 2019. His son, resident in Lombardy, now gives instructions through a Ticino fiduciary who acts as director of the company. The account receives occasional transfers from a construction company in Lombardy and sends funds to a real estate company in the Mendrisiotto. Italian newspapers report that the construction company has been excluded from public contracts by an anti-Mafia prefectoral measure.
The warning signs are the change of beneficial owner without a new declaration, the link to a sector named by the MROS, and an Italian administrative measure that indicates suspected infiltration. The bank must update the client documentation under Article 7(1bis) AMLA and obtain a new declaration of the beneficial owner. It must clarify the background under Article 6(2) AMLA and, if the suspicion cannot be dispelled, report under Article 9 AMLA. The fiduciary is a financial intermediary under Article 2(3) AMLA, because he has signing authority over the account, and is subject to the same duties through his SRO.
Typology 2: the cash purchase in the Mendrisiotto
A buyer resident in Italy wants to purchase a flat in a Ticino border village for CHF 850,000. He proposes to pay CHF 250,000 in cash on signing and the balance from an account at an Italian bank. The seller's estate agent and the notary are asked to accept the cash. The buyer's company in Italy operates restaurants. Its accounts show low profits.
Since 1 October 2026 a cash payment of more than CHF 100,000 in a real estate transaction must be made through a financial intermediary. An adviser who assists with the transaction may be subject to due diligence duties under the revised AMLA. The bank that receives the cash will apply its own rules on cash deposits and, given the restaurant business, the profile of the buyer and the cross-border origin of the funds, will usually require documentary evidence of the source of the cash before accepting it. The case resembles the patterns named by the MROS for the catering and real estate sectors.1
Notes
- MROS, Annual Report 2025 (above), section 4.3; Art. 8a AMLA (above) and WEKA (above) for the thresholds. ↩
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.