Sectors at risk: fiduciaries, domiciliary companies, real estate, cash and gold

What the national risk assessment found

Switzerland's national risk assessments provide the official baseline for the risk-based approach. The first report was published in June 2015 by the Interdepartmental Coordinating Group on Combating Money Laundering and the Financing of Terrorism (CGMF). It identified fraud and embezzlement, corruption and participation in a criminal organization as the main predicate offences. It rated universal banks, private banking, asset management, the legal professions, fiduciaries, money transmitters and retail banks as sectors of medium risk.¹ The second report, dated August 2021 and published by the Federal Department of Finance on 29 October 2021, concluded that the considerable risk to which Switzerland is exposed had not changed fundamentally since 2015. Its main vulnerability lies in the laundering of proceeds of offences committed abroad, which follows from the international orientation of the financial centre.²

The report of 2021 analysed the reports received by the MROS between 2015 and 2019. Bribery had become the leading predicate offence with 28.95 per cent of the reports, followed by fraud with 26.63 per cent, misappropriation with 7.96 per cent and criminal organization with 7.75 per cent. Aggravated tax misdemeanours, a predicate offence since 2016, accounted for 4.01 per cent. The average number of reports per year had risen from 1,113 in the period 2004–2014 to 4,758 in 2015–2019. Foreign contracting parties were involved in 60.4 per cent of the reports.³ The report rated asset managers and fiduciaries and lawyers as sectors of high exposure, observing that the low number of reports from fiduciaries and lawyers suggested a significant gap, and it identified real estate and commodity trading as exposed sectors outside the AMLA's direct scope.⁴

Domiciliary companies

The most important single risk factor in the national assessment is the domiciliary company. It is a legal entity without a genuine business of its own, typically incorporated in an offshore jurisdiction and administered through a fiduciary or a lawyer, which holds a bank account in Switzerland. The share of reports involving domiciliary companies rose from 17.10 per cent in 2004–2014 to 29.55 per cent in 2015– 2019. In reports concerning bribery the share was 43.36 per cent, and in reports concerning criminal organizations 43 per cent. The companies were typically registered in Central America and the Caribbean, and their beneficial owners were often concealed behind nominees.⁵

The figures have particular weight in Lugano, where the administration of domiciliary companies for Italian clients was for decades a central business of fiduciaries, as Chapters D.II and E.III describe. The structure that served the legitimate purpose of discretion and the less legitimate purpose of concealing undeclared assets from the Italian tax authorities is the same structure that a criminal organization needs to separate its money from the names of its members. The CDB 20 requires banks to establish the beneficial owner of domiciliary companies on the basis of a written declaration, the so-called Form A, and FINMA's guidance treats complex structures as a factor of increased risk.⁶ The transparency register introduced on 1 October 2026 applies to Swiss legal entities and to foreign entities with a branch, their effective management or real estate in Switzerland. It therefore reaches the Swiss sub-holding of an Italian family. A Panamanian or British Virgin Islands company that only holds a bank account in Lugano falls outside it, and for such companies the declaration to the bank remains the decisive control.

Notes

1. "Money laundering risks", SAVE news, summary of the first national risk assessment of June 2015, https://news.save.ch/en/?p=3106. ↩
2. CGMF, Report on the national assessment of the risks of money laundering and terrorist financing in Switzerland, August 2021 (above); State Secretariat for International Finance (SIF), "Second national report on money laundering and terrorist financing risks", 29 October 2021, https://sif.admin.ch/en/national-report-money-laundering-terrorist-financing. ↩
3. CGMF, Report 2021 (above). ↩
4. CGMF, Report 2021 (above). ↩
5. CGMF, Report 2021 (above). ↩
6. Swiss Bankers Association, Agreement on the Swiss banks' code of conduct with regard to the exercise of due diligence (CDB 20), in force since 1 January 2020, Arts. 27–28 (establishing the beneficial owner, Form A) and Art. 39 (domiciliary companies), https://www.swissbanking.ch/_Resources/Persistent/6/2/e/e/62eec3df0685e359c5a376dfca79dec8b90 8ea9c/SBA_Agreement_CDB_2020_EN.pdf; FINMA Guidance 04/2026 as summarized by Grant Thornton (above). ↩

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 October 2026.