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# Switzerland — Beneficial Ownership and Corporate Transparency | Financial Integrity Monitor

Switzerland (CH) · Module Detail

# Switzerland: Beneficial Ownership and Corporate Transparency

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#### Beneficial Ownership and Corporate Transparency

Continue reading Globally, the EU AML Package, comprising the directly applicable AML Regulation (Reg (EU) 2024/1624), the sixth AML Directive transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority, sets the structural direction for beneficial-ownership transparency, with supervision shifting from purely national authorities toward a hybrid EU-level regime under AMLA's direct and indirect supervision perimeter. Switzerland sits outside this package: as a non-EEA jurisdiction, it has no incorporation mechanism through which the AMLR, 6AMLD or AMLA Regulation reach Swiss entities, and the directly relevant development for Switzerland is instead a wholly domestic transparency reform.

The revised Anti-Money Laundering Act and the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TJPG) entered into force on 1 October 2026. Together these establish a non-public federal beneficial-ownership register, with a disclosure threshold set at ownership or control exceeding twenty-five percent, and extend anti-money-laundering duties to lawyers, notaries and other professional advisors performing defined high-risk activities. This is a structural finding, not an incident: it changes who must identify and record beneficial owners, and it changes the population of professional facilitators now brought within the Swiss AML perimeter, even though the register itself remains non-public and provisions concerning state notaries are deferred pending cantonal implementation.

The third national risk assessment, on which the Federal Council was briefed on 14 October 2026, is directly relevant context for this reform. That assessment found Switzerland's overall money-laundering and terrorist-financing risk exposure stable, but identified organised crime, corruption, and property and tax crime, each with an international dimension, as the leading threats. Legal-entity opacity is a documented vector within each of those threat categories, and the TJPG register is the structural response to that vector being flagged as a leading, not marginal, concern.

The near-term test of the reform's substance rather than its formal commencement is the FINMA AMLO-FINMA partial revision, which is not itself a D2 instrument but bears directly on beneficial-ownership traceability: its draft Art. 9b and Art. 37(5) provisions require financial intermediaries to document ownership and control-structure traceability as part of sanctions-circumvention screening, which operationalises for financial-sector gatekeepers a traceability duty that parallels the TJPG register's incorporation-level disclosure duty for legal and notarial advisors. The consultation on that revision closed on 9 June 2026 and the ordinance is expected to enter into force on 1 January 2027.

#### Outlook

The period before Switzerland's fifth-round FATF mutual evaluation, scheduled for 2026 to 2027, is the window in which the TJPG register's practical operation, not merely its formal commencement, will be tested. The register has been operating via EasyGov since 1 October 2026, which gives assessors a limited but real track record to examine by the time the evaluation proceeds. Deferred provisions concerning state notaries, implemented at cantonal level, remain an open item whose resolution will determine how completely the professional-advisor extension of AML duties is realised in practice.