Reporting to the MROS: law, statistics and the Ticino share

The duty and the right to report

Chapter D.IV described how the right to report of 1994 and the duty to report of 1997 came into being. Under the law as it stands today, a financial intermediary must report immediately to the MROS in four situations. The duty arises if it knows or has reasonable grounds to suspect that assets involved in a business relationship are connected with an offence under Article 260ter or 305bis of the Swiss Criminal Code (SCC), derive from a felony or an aggravated tax misdemeanour, are subject to the power of disposal of a criminal or terrorist organization, or serve to finance terrorism. The same applies when it breaks off negotiations on a business relationship because of such a suspicion. Reasonable grounds exist if the intermediary has specific evidence or several indications that one of these conditions may be met and cannot dispel the suspicion by additional clarifications. Lawyers and notaries are not subject to the duty insofar as their activity is covered by professional secrecy (Art. 9 AMLA).¹ Alongside the duty, the right to report under Article 305ter(2) SCC remains available for observations below the threshold of reasonable suspicion.

The revision in force since 1 January 2023 changed the consequences of a report. The intermediary no longer has to freeze the assets automatically on reporting. Instead, the freeze follows only when the MROS forwards the report to a prosecution authority. If the MROS does not inform the intermediary within 40 working days that it has forwarded the information, the intermediary may terminate the relationship. It must inform the MROS of the termination without delay and must continue to observe the prohibition of tipping off (Art. 9b AMLA).² The number of such termination notices rose from 2,669 in 2023 to 7,118 in 2024 and 7,770 in 2025, according to the MROS.³ For a Lugano bank the rule creates a practical choice after every report. It must decide whether to continue a relationship under enhanced monitoring or to terminate it once the 40 days have passed, documenting how the assets leave the bank so that the money trail remains traceable.

The growth of reports since 2020

The number of reports has grown steeply since the MROS introduced the goAML electronic reporting system in January 2020. The MROS received 5,334 reports in 2020, 5,964 in 2021, 7,639 in 2022, 11,876 in 2023 and 15,141 in 2024, an average of 59 reports per working day in the last of these years.⁴ In 2025 the figure reached 21,087, an increase of 39.3 per cent over the previous year and an average of 82 reports per working day.⁵ The growth reflects several factors. They include the clarification of the reporting threshold in 2023 and the use of the termination rule of Article 9b AMLA, together with the inclusion of new categories of reporting entities such as providers of services in Kryptowerte und Digital Assets, the spread of online investment fraud and the general tightening of supervisory expectations after the cases described below. The MROS itself, which had four employees when it was founded in 1998, had about 55 in 2024 and about 57 full-time equivalents in 2025.⁶

Year Reports received Cases forwarded Of which to Ticino 2010 1,159 n/a n/a 2018 6,126 2,368 78 2022 7,639 1,232 n/a 2024 15,141 1,043 57 2025 21,087 1,375 47

The table combines figures from the MROS annual reports for 2010, 2018, 2022, 2024 and 2025.⁷ The figures for cases forwarded are not fully comparable across the years, because the MROS changed its method of counting with the introduction of goAML and now forwards analysed cases that may combine several reports. In 2024 the average was 1.9 reports per forwarded case.⁸

Notes

Art. 9 AMLA, https://www.droit-bilingue.ch/en-de/9/95/955.0-9-15.html (para. 1quater in force since 1 January 2023). ↩
Art. 9b AMLA, https://www.droit-bilingue.ch/en-de/9/95/955.0-9b-17.html (inserted by the Federal Act of 19 March 2021, AS 2021 656, in force since 1 January 2023). The replacement of the automatic freeze on reporting by a freeze on forwarding (Art. 10 AMLA) is summarized from the revision of 2021; see also Chapter D.IV. ↩
Money Laundering Reporting Office Switzerland (MROS), Annual Report 2025 , Federal Office of Police, May 2026, 26, https://www.fedpol.admin.ch/dam/en/sd-web/05JKPvNkIrsY/jb-mros-2025-e.pdf. ↩
MROS, Jahresbericht 2024 , fedpol, 2025, 15, https://www.fedpol.admin.ch/dam/fedpol/de/data/kriminalitaet/geldwaescherei/jabe/jb-mros-2024.pdf.download.pdf/jb-mros-2024-d.pdf. ↩
MROS, Annual Report 2025 (above), 16–17. ↩
MROS, Jahresbericht 2024 (above), 10; MROS, Annual Report 2025 (above), 10. ↩
MROS, Rapporto d'attività 2010 , 27, https://www.ejpd.admin.ch/dam/fedpol/it/data/kriminalitaet/geldwaescherei/jabe/jb-mros-2010-i.pdf.download.pdf/jb-mros-2010-i.pdf; MROS, Rapporto d'attività 2018 , https://www.bj.admin.ch/dam/fedpol/it/data/kriminalitaet/geldwaescherei/jabe/jb-mros-2018-i.pdf.download.pdf/jb-mros-2018-i.pdf; MROS, Rapporto annuale 2022 , https://www.ejpd.admin.ch/dam/fedpol/it/data/kriminalitaet/geldwaescherei/jabe/jb-mros-2022.pdf.download.pdf/jb-mros-2022-i.pdf; MROS, Jahresbericht 2024 (above), 20; MROS, Annual Report 2025 (above), 22. The 2025 report gives the 2024 total of forwarded cases as 1,046. ↩
MROS, Jahresbericht 2024 (above), 20. ↩

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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Reporting to the MROS: law, statistics and the Ticino share

The duty and the right to report

The growth of reports since 2020

Notes

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