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AML and Compliance

AML and Compliance

Switzerland applies strict rules against money laundering, and they reach well beyond the banks. The articles collected here explain the Anti-Money Laundering Act, the offence of money laundering under Article 305bis of the Criminal Code, the reporting duty and the right to report to MROS, the due diligence expected of financial intermediaries and trading houses, and the return of illicit assets. They also cover the revision of the Anti-Money Laundering Act and the new federal transparency register that apply from 1 October 2026, and what they mean for foreign groups with Swiss companies.

Rules that reach beyond the banks

Swiss anti-money laundering law applies to banks and to every other financial intermediary, and its principles shape the expectations of trading houses, fiduciaries and advisers. Since 1 October 2026 it also covers certain advisory activities and is complemented by a federal register of beneficial owners.

For a foreign company, these rules become visible long before any question of wrongdoing arises. Swiss banks will ask about the beneficial owner, the origin of the funds and the purpose of the business relationship when an account is opened, and they will expect plausible documentation whenever transactions change in size or pattern. Preparing these documents early saves considerable time and avoids frustration.

Key questions for foreign companies

The first question is whether the company's own activity makes it a financial intermediary under the Anti-Money Laundering Act, which may be the case for payment services, asset management or the custody of crypto assets. If so, it must be affiliated with a recognised self-regulatory organisation or be supervised by FINMA, and it must establish internal know-your-customer procedures.

The second question concerns counterparties. Commodity traders, fiduciaries and advisers are expected to understand with whom they deal, to recognise indications of sanctions exposure or corruption and to document their assessment. Clear internal rules, regular training for staff and an orderly client file are the practical means by which a company shows that it has taken these expectations seriously.

In this section

The articles explain the Anti-Money Laundering Act, the reporting duty to MROS, the due diligence expected in commodity trading, the return of illicit assets to their countries of origin, and the new transparency and anti-money laundering rules that apply from October 2026.

Philanthropy · International

Cross-border giving: international donors and Swiss foundations

Philanthropy is increasingly international. Families from Asia, the Middle East, Africa and Latin America establish foundations in Switzerland to support… Read more
Digital Assets · Practice

Licences for crypto businesses in Switzerland

Switzerland does not have a single crypto licence. A crypto business needs the licence that corresponds to what it actually… Read more
AML and Compliance · New Law

From 1 October 2026: the transparency register and the revised Anti-Money Laundering Act

On 1 October 2026 the Federal Act on the Transparency of Legal Entities and the revision of the Anti-Money Laundering… Read more
Africa · Sanctions

Chinese shareholders, US sanctions and the BIS Affiliates Rule

A Swiss company with Chinese shareholders that does business in Africa has to consider three sets of rules: Swiss sanctions,… Read more
Corporate Structures · Practice

Domiciliary companies in Switzerland: why the BVI company with a Swiss address has had its day

For decades, a familiar structure for investors from Asia, the Middle East, Africa and Latin America was a company incorporated… Read more
Asset Recovery · Practice

Returning illicit assets: the procedure under the 2015 Act

According to the Federal Department of Foreign Affairs, Switzerland has returned more than USD 2 billion of illicit assets of… Read more
AML and Compliance · Practice

Reporting to MROS: duty, right and procedure

Every Swiss financial intermediary that develops a well-founded suspicion of money laundering must report it to the Money Laundering Reporting… Read more
Commodity Trading · Asset Recovery

Geneva and Africa: commodities, elites and the return of illicit assets

Few relationships of the Geneva financial centre are as old, as dense and as contested as the one with Africa. Read more
AML and Compliance · Commodities

Anti-money-laundering in commodity trading: reporting duties and corporate criminal liability

Commodity trading touches states in which payments to officials are part of the business model of local intermediaries. Swiss law… Read more