--- title: "Switzerland (CH) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/switzerland/ source_html: /jurisdictions/switzerland/index.html description: "Financial integrity intelligence for Switzerland (CH): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 8ea211a992a09342b4436a44851a1a1ea94fe2e22946ae5349fe20e895a6a536 generator: "fe-fleet/md-twin@1.0" --- # Switzerland (CH) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Switzerland CH Domains covered 8 of 8 Sources 207 Role actions 8 Horizon <90d 3 Jurisdiction profile FATF status: Largely Compliant Tier: A Risk direction: Stable Enablement vs enforcement: Mixed Switzerland's AML/CFT regime rests on the Anti-Money Laundering Act (GwG), FINMA supervision, and MROS reporting. More FATF rates it compliant/largely compliant on 37 of 40 recommendations, but beneficial ownership transparency remains unimplemented, gatekeeper (lawyer/notary) AML duties are limited, and Banking Act Article 47 secrecy provisions chill investigative disclosure. Key deficiencies - No operative federal beneficial ownership register despite a 2023 draft bill - Lawyers, notaries and fiduciaries largely outside AML due-diligence obligations - Banking Act Article 47 criminalises disclosure of client data, deterring whistleblowing and press scrutiny - FINMA historically lacked power to directly fine banks (reform only proposed mid-2025) - Geneva/Zug commodity-trading hub structurally exposed to sanctions-evasion intermediation Recent developments (18m) - FINMA investigation into Bank Reyl's handling of high-risk PEP accounts revealed via leaked correspondence (April 2025) - SECO raid on metals trader Open Mineral AG over Russian gold sanctions breaches (September 2025) - Federal Council proposal to grant FINMA bank-fining powers (June 2025) - OFAC-SECO Memorandum of Understanding on sanctions cooperation (May 2025) - Swiss Supreme Court ruling on unlawful confiscation method in the Magnitsky-linked case (December 2025) followed by a Council of Europe Parliamentary Assembly resolution rebuking Switzerland's failure to act (April 2026) - MBaer Merchant Bank shut down and placed under preliminary Swiss criminal probe following US money-laundering allegations tied to Iran (April 2026) Brief ## Lead signal #### Lead Signal Switzerland crossed two structural thresholds in quick succession this cycle. The revised Anti-Money Laundering Act (GwG, SR 955.0) and the new Transparency of Legal Entities Act (TJPG) both entered into force on 1 October 2026, extending customer due-diligence duties to a defined set of advisors and, for the first time, establishing a non-public federal beneficial-ownership register administered by the Federal Office of Justice. Days later, FINMA confirmed that a separate but related instrument, Circular 2016/7 on video and online identification, will take effect on 1 November 2026 in its partially revised form. That revision admits the Swiss e-ID as a valid basis for online identification, treats QR-coded identity documents as equivalent to machine-readable-zone documents, and adds a liveness-detection requirement that FINMA itself frames as a direct response to AI-driven impersonation risk in digital onboarding. Read full brief #### Lead Signal Switzerland crossed two structural thresholds in quick succession this cycle. The revised Anti-Money Laundering Act (GwG, SR 955.0) and the new Transparency of Legal Entities Act (TJPG) both entered into force on 1 October 2026, extending customer due-diligence duties to a defined set of advisors and, for the first time, establishing a non-public federal beneficial-ownership register administered by the Federal Office of Justice. Days later, FINMA confirmed that a separate but related instrument, Circular 2016/7 on video and online identification, will take effect on 1 November 2026 in its partially revised form. That revision admits the Swiss e-ID as a valid basis for online identification, treats QR-coded identity documents as equivalent to machine-readable-zone documents, and adds a liveness-detection requirement that FINMA itself frames as a direct response to AI-driven impersonation risk in digital onboarding. Taken together, the two developments describe a single architectural move rather than two unrelated ones: Switzerland has simultaneously tightened who must identify a customer, who that customer's beneficial owner is deemed to be, and how the identification itself is technically performed. The entry into force of the GwG and TJPG closes an advisor-perimeter gap that had previously been raised in FATF-adjacent commentary, while the Circular 2016/7 revision modernises the evidentiary basis on which that extended perimeter of obliged entities performs its duties. Separately, FINMA approved Switzerland's first retail Bitcoin exchange-traded fund on 20 October 2026, applying custody guidance it issued earlier in the year and granting an exemption from standard fund risk-diversification rules to accommodate the product's structure. #### Other Developments A federal beneficial-ownership register now exists. Prior to 1 October 2026, Switzerland identified beneficial owners contractually, intermediary by intermediary, with no central federal register. The TJPG creates one, non-public, with staggered first-filing deadlines running from three months to two years depending on entity form, and a parallel six-month deadline for newly-captured advisors to apply to a recognised self-regulatory organisation. This is a transparency-architecture change, not an enforcement event, and its significance sits in the existence of the register itself rather than in any single filing. The advisor perimeter under the GwG has widened. The revised Act extends due-diligence duties to a defined set of advisors who were previously outside its scope, with a carve-out for lawyers and notaries acting within judicial, administrative or arbitration proceedings. This closes a gap that enabler-jurisdiction commentary has previously identified in Switzerland's framework, without any single enforcement action driving the change. FINMA approved the first retail Bitcoin ETF. The approval on 20 October 2026 applied FINMA's own January 2026 crypto-custody guidance as the operational template, and FINMA granted an exemption from the fund's standard risk-diversification requirements to permit the structure. This is an episodic regulatory-approval event rather than a change to the standing legal framework governing digital assets, but it signals that the custody guidance issued earlier in the year is now being used as working precedent. Digital identification standards have been modernised ahead of the AML regime they support. The Circular 2016/7 revision, due in force 1 November 2026, lets obliged entities rely on the Swiss e-ID and treat QR-coded documents as MRZ-equivalent, while adding liveness detection explicitly to counter AI-driven impersonation. Firms whose onboarding flows still depend solely on legacy MRZ or chip-read document checks will need to assess how e-ID and liveness-detection integration map onto the baseline this revision sets. #### Cross-Monitor Connections The beneficial-ownership register and the widened advisor perimeter both bear on how professional facilitators are positioned relative to corporate-opacity structures, a question that recurs wherever enabler-jurisdiction analysis and conflict-finance tracing intersect: a non-public register raises the question of who outside the obliged-entity population can actually query it, which is a different transparency proposition from a public register even where the underlying filing obligation is comparably strict. The Bitcoin ETF approval is relevant wherever digital-asset custody and institutional product wrappers are tracked as a vector for licit capital intersecting with less transparent crypto infrastructure, since a retail-accessible, FINMA-supervised wrapper changes the on-ramp available to institutional money relative to direct token holding. The Circular 2016/7 liveness-detection requirement is the clearest point of contact with technology-driven identity-fraud and deepfake-impersonation concerns tracked elsewhere, since FINMA's own framing ties the requirement directly to AI impersonation risk in remote onboarding rather than to a conventional document-fraud typology. #### Outlook Two further instruments are in the pipeline and neither has yet taken effect. A Federal Council and State Secretariat for International Finance proposal would replace the 2018 FinTech licence with a dedicated payment-instrument-institution licence, removing its CHF 100 million deposit cap and creating a route for issuing Stable Payment Crypto-Assets, alongside a separate crypto-institution licence for custody and trading services; this remains at consultation stage with an expected timeline of early 2027 and should be read as scheduled rather than assured. Separately, a partial revision of the Anti-Money Laundering Ordinance (AMLO-FINMA), aimed at embedding Embargo Act coercive-measures compliance as an organisational duty, had its consultation close in June 2026 and is planned to take effect on 1 January 2027, though the final text had not been reported as at this cycle. Switzerland's mutual evaluation under the FATF's fifth round is scheduled with a possible onsite visit around mid-2027. None of these pending items change the assessment that Switzerland's immediate trajectory this cycle is toward tightened technical compliance architecture rather than toward any new enforcement or grey-list exposure. Earlier periodic briefs (8) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal Switzerland crossed two structural thresholds in quick succession. The revised Anti-Money Laundering Act (GwG, SR 955.0) and the new Transparency of Legal Entities Act (TJPG) both entered into force on 1 October 2026, extending customer due-diligence duties to a defined set of advisors and, for the first time, establishing a non-public federal beneficial-ownership register administered by the Federal Office of Justice. Days later, FINMA confirmed that a separate but related instrument, Circular 2016/7 on video and online identification, will take effect on 1 November 2026 in its partially revised form. That revision admits the Swiss e-ID as a valid basis for online identification, treats QR-coded identity documents as equivalent to machine-readable-zone documents, and adds a liveness-detection requirement that FINMA itself frames as a direct response to AI-driven impersonation risk in digital onboarding. Taken together, the two developments describe a single architectural move rather than two unrelated ones: Switzerland has simultaneously tightened who must identify a customer, who that customer's beneficial owner is deemed to be, and how the identification itself is technically performed. The entry into force of the GwG and TJPG closes an advisor-perimeter gap that had previously been raised in FATF-adjacent commentary, while the Circular 2016/7 revision modernises the evidentiary basis on which that extended perimeter of obliged entities performs its duties. Separately, FINMA approved Switzerland's first retail Bitcoin exchange-traded fund on 20 October 2026, applying custody guidance it issued earlier in the year and granting an exemption from standard fund risk-diversification rules to accommodate the product's structure. #### Other Developments A federal beneficial-ownership register now exists. Prior to 1 October 2026, Switzerland identified beneficial owners contractually, intermediary by intermediary, with no central federal register. The TJPG creates one, non-public, with staggered first-filing deadlines running from three months to two years depending on entity form, and a parallel six-month deadline for newly-captured advisors to apply to a recognised self-regulatory organisation. This is a transparency-architecture change, not an enforcement event, and its significance sits in the existence of the register itself rather than in any single filing. The advisor perimeter under the GwG has widened. The revised Act extends due-diligence duties to a defined set of advisors who were previously outside its scope, with a carve-out for lawyers and notaries acting within judicial, administrative or arbitration proceedings. This closes a gap that enabler-jurisdiction commentary has previously identified in Switzerland's framework, without any single enforcement action driving the change. FINMA approved the first retail Bitcoin ETF. The approval on 20 October 2026 applied FINMA's own January 2026 crypto-custody guidance as the operational template, and FINMA granted an exemption from the fund's standard risk-diversification requirements to permit the structure. This is an episodic regulatory-approval event rather than a change to the standing legal framework governing digital assets, but it signals that the custody guidance issued earlier in the year is now being used as working precedent. Digital identification standards have been modernised ahead of the AML regime they support. The Circular 2016/7 revision, due in force 1 November 2026, lets obliged entities rely on the Swiss e-ID and treat QR-coded documents as MRZ-equivalent, while adding liveness detection explicitly to counter AI-driven impersonation. Firms whose onboarding flows still depend solely on legacy MRZ or chip-read document checks will need to assess how e-ID and liveness-detection integration map onto the baseline this revision sets. #### Cross-Monitor Connections The beneficial-ownership register and the widened advisor perimeter both bear on how professional facilitators are positioned relative to corporate-opacity structures, a question that recurs wherever enabler-jurisdiction analysis and conflict-finance tracing intersect: a non-public register raises the question of who outside the obliged-entity population can actually query it, which is a different transparency proposition from a public register even where the underlying filing obligation is comparably strict. The Bitcoin ETF approval is relevant wherever digital-asset custody and institutional product wrappers are tracked as a vector for licit capital intersecting with less transparent crypto infrastructure, since a retail-accessible, FINMA-supervised wrapper changes the on-ramp available to institutional money relative to direct token holding. The Circular 2016/7 liveness-detection requirement is the clearest point of contact with technology-driven identity-fraud and deepfake-impersonation concerns tracked elsewhere, since FINMA's own framing ties the requirement directly to AI impersonation risk in remote onboarding rather than to a conventional document-fraud typology. #### Outlook Two further instruments are in the pipeline and neither has yet taken effect. A Federal Council and State Secretariat for International Finance proposal would replace the 2018 FinTech licence with a dedicated payment-instrument-institution licence, removing its CHF 100 million deposit cap and creating a route for issuing Stable Payment Crypto-Assets, alongside a separate crypto-institution licence for custody and trading services; this remains at consultation stage with an expected timeline of early 2027 and should be read as scheduled rather than assured. Separately, a partial revision of the Anti-Money Laundering Ordinance (AMLO-FINMA), aimed at embedding Embargo Act coercive-measures compliance as an organisational duty, had its consultation close in June 2026 and is planned to take effect on 1 January 2027, though the final text had not been reported as. Switzerland's mutual evaluation under the FATF's fifth round is scheduled with a possible onsite visit around mid-2027. None of these pending items change the assessment that Switzerland's immediate trajectory is toward tightened technical compliance architecture rather than toward any new enforcement or grey-list exposure. 3 Nov 2026 · fim-2026-11-02 #### Lead Signal Switzerland's structural anti-money-laundering architecture moved on two fronts at once. The revised Anti-Money Laundering Act (GwG; SR 955.0) and the Transparency of Legal Entities Act (TJPG, SR 955.3) both entered into force on 1 October 2026, giving the country its first-ever federal, non-public beneficial-ownership register, run by the Federal Office of Justice. The same revision pulls trustees, lawyers acting in a structuring capacity, real-estate brokers and domiciliary-address providers inside the formal anti-money-laundering perimeter for the first time, closing a gap previously flagged in Financial Action Task Force assessments. Newly captured advisors have six months from the 1 October 2026 entry into force to apply to a recognised self-regulatory organisation. Alongside the ownership-transparency shift, the supervisory authority FINMA approved Switzerland's first retail Bitcoin exchange-traded fund on 20 October 2026, issued by BIT Asset Management AG, granting an exemption from standard fund risk-diversification rules on the basis of Bitcoin's trading history and liquidity, subject to custody safeguards set out in FINMA guidance issued in January 2026. #### Other Developments Digital identification rules take effect. FINMA Circular 2016/7 on video and online identification, as revised, enters into force on 1 November 2026. The revision admits the Swiss electronic identity as a valid means of online identification, treats QR-coded identity documents as equivalent to machine-readable-zone documents, and adds a liveness-detection requirement aimed at artificial-intelligence-driven impersonation risk. The obligation reaches banks, payment companies, crypto-asset operators and investment firms engaged in anti-money-laundering-compliant digital client onboarding. Sanctions compliance architecture remains at the consultation stage. The partially revised Anti-Money Laundering Ordinance of FINMA, which builds out the Embargo Act coercive-measures compliance architecture for financial intermediaries, remains where it stood after its consultation closed: it did not advance to force and is expected around 1 January 2027. Mutual evaluation schedule confirmed. Switzerland is to undergo its fifth country review by the Financial Action Task Force across 2026 and 2027, a standing item on the compliance calendar rather than a new development, but one that gives the advisor-perimeter and beneficial-ownership changes above added salience as examiners prepare to test implementation. #### Cross-Monitor Connections The beneficial-ownership register and the widened advisor perimeter both sit squarely at the intersection of enabler-jurisdiction analysis and corporate-transparency tracking elsewhere in the fleet: a jurisdiction that has historically relied on professional secrecy norms has now placed lawyers, trustees and domiciliary-address providers under a registration duty, which is the kind of structural change that state-capture and conflict-finance tracking elsewhere treats as a leading indicator of reduced layering capacity through Swiss vehicles. The Bitcoin exchange-traded fund approval is commercial in form but carries an integrity dimension worth routing to crypto-asset monitoring generally: a first-of-its-kind product approval, paired with custody guidance rather than a bespoke licensing regime, signals that the supervisor is willing to extend conventional fund-diversification exemptions to a digital asset ahead of the broader licensing reform still sitting in consultation. #### Outlook The near-term test is implementation rather than legislation. The six-month window for newly captured advisors to join a recognised self-regulatory organisation runs from 1 October 2026, and the digital-identification circular takes effect from 1 November 2026, so the next reporting cycle should show whether onboarding systems and advisor registrations have caught up with the law on the books. The Embargo Act compliance-architecture revision remains a consultation-stage item pointed at 1 January 2027 and has not moved; it is a item to watch rather than one that changed. The broader Financial Institutions Act reform that would create dedicated payment-instrument and crypto-institution licence categories, including a stable-payment-crypto-asset issuance regime, also remains at a pre-dispatch stage with a wide uncertainty band, as scheduled for around the first quarter of 2027. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Switzerland's financial-integrity architecture moved on two structural fronts at once. The Swiss Transparency Register, established under the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, began operations on 1 October 2026, giving the country a central, non-public beneficial-ownership register for the first time. In parallel, Article 8 of the Anti-Money Laundering Act now explicitly requires financial intermediaries to take organisational measures to prevent breaches of coercive measures under the Embargo Act, a codification that took effect the same day. Together these developments tighten two of the most structurally significant gaps in the Swiss regime: corporate-ownership opacity and the absence of an explicit statutory sanctions-organisation duty sitting inside the AML statute itself. Separately, FINMA concluded enforcement proceedings against Julius Baer over private loans to a European group and business ties with two Russian politically exposed persons, the bank's fifth such case in a decade, with a capital add-on and a fine reported at CHF 10 million. The Transparency Register finding carries the most durable consequence for the jurisdiction's standing position. Switzerland has historically been criticised in professional-enabler and corporate-opacity assessments for lacking a central ownership record; the new register, however non-public its initial design, converts a long-standing structural gap into a registered, trackable obligation for every legal entity caught by the reporting duty. The AMLA Article 8 codification is probable in confidence rather than confirmed, since the only material retrieved was third-party commentary rather than the Federal Council's or FINMA's own ordinance text, but the direction is consistent: Switzerland is formalising, inside its autonomous AML statute, an organisational duty to prevent sanctions breaches that previously sat more loosely across guidance and SECO ordinances. #### Other Developments Repeat enforcement against a major private bank underscores persistent PEP risk. FINMA's conclusion of proceedings against Julius Baer, its fifth enforcement action against the lender in ten years, again centred on relationships with politically exposed persons and private lending practices connected to a European group. The repetition is itself a signal: supervisory attention to PEP-relationship controls in Swiss private banking remains active even as the broader AML framework is being reinforced elsewhere. FATF mutual evaluation now has a concrete calendar. Switzerland's fifth-round FATF mutual evaluation carries a possible onsite assessment period from June 2027 and a possible plenary discussion in February 2028, according to FATF's own assessment calendar. This gives the jurisdiction a known horizon against which to demonstrate that the newly codified sanctions-organisation duty and the new Transparency Register are operating in practice, rather than merely on paper, by the time assessors arrive. #### Cross-Monitor Connections The Transparency Register's entry into operation is directly relevant to work tracking corporate-structure opacity and professional-enabler exposure, since a functioning central beneficial-ownership record changes what due-diligence and law-enforcement requests can establish about Swiss-registered entities going forward. The AMLA Article 8 codification intersects with sanctions-architecture tracking more broadly: Switzerland continues to implement UN and case-by-case EU measures autonomously through SECO under the Embargo Act, and an explicit statutory organisational duty strengthens the domestic enforcement hook behind that autonomous posture without changing its independence from the EU sanctions list. The Julius Baer enforcement action is relevant to monitoring of financial-institution conduct risk in jurisdictions that combine a sophisticated private-banking sector with a history of repeat, rather than first-time, supervisory findings against the same institution. #### Outlook The period ahead is likely to test whether the Transparency Register's registration rates and the AMLA Article 8 organisational duty produce verifiable in-practice outcomes ahead of the FATF onsite period, as scheduled for 2027. Until a Federal primary text on the Article 8 amendment is retrieved and reviewed directly, confidence in its precise scope and enforcement mechanics should remain at the probable tier rather than confirmed. The Julius Baer matter, given the bank's enforcement history, is also a marker worth watching for whether FINMA escalates toward more structural remedial requirements in future cycles rather than recurring financial penalties alone. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Switzerland's anti-money-laundering architecture is in a period of active structural tightening even as its own risk posture is assessed as unchanged. The Federal Council was briefed on 14 October 2026 on the third national risk assessment produced by the Coordinating Group on Combating Money Laundering and the Financing of Terrorism, which found overall money-laundering and terrorist-financing risk exposure stable, with the leading threats identified as organised crime, corruption, and property and tax crime, each carrying an international dimension. That finding of stability sits alongside two structural developments that have already reshaped the Swiss regime: 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, establishing a non-public federal beneficial-ownership register with a disclosure threshold set at more than twenty-five percent ownership or control, and extending anti-money-laundering duties to lawyers, notaries and other advisors performing defined high-risk activities. The combination is the headline: a regulator describing threat levels as stable while simultaneously bedding in the most significant transparency reform in the Swiss AML framework in years, timed ahead of the country's fifth-round FATF mutual evaluation scheduled for 2026 to 2027. #### Other Developments FINMA's ordinance-level revision advances toward a 2027 in-force date. The partial revision of the Anti-Money Laundering Ordinance of FINMA (AMLO-FINMA), covering sanctions-circumvention screening, ownership and control-structure traceability, and enhanced correspondent-banking and payable-through-account controls under draft Art. 9b and Art. 37(5), completed its consultation on 9 June 2026 and is expected to enter into force on 1 January 2027. The revision codifies existing supervisory practice rather than introducing novel obligations, but its timing ahead of the mutual evaluation window is notable: financial intermediaries will face an explicit ordinance-level duty to screen for sanctions circumvention and document beneficial-ownership traceability where that duty was previously a matter of supervisory expectation rather than binding text. A September referendum preserved the Federal Council's sanctions-alignment discretion. Swiss voters rejected a proposal to enshrine a stricter definition of neutrality in the constitution, an outcome that leaves intact the Federal Council's existing discretion to align with EU and UN sanctions measures, including those concerning Russia. The result does not change Switzerland's sanctions posture; it forecloses a route by which that posture might have been constrained going forward. Switzerland's FATF compliance rating remains a mixed but largely favourable standing position. Switzerland is currently rated compliant on eight FATF Recommendations, largely compliant on twenty-nine, and partially compliant on three. This rating predates the fifth-round mutual evaluation and forms the baseline against which the AMLO-FINMA revision and the TJPG commencement will be tested when that evaluation proceeds. #### Cross-Monitor Connections The TJPG beneficial-ownership register and its extension of due-diligence duties to legal and notarial advisors intersect with the enabler-jurisdiction and professional-facilitator concerns tracked elsewhere in this fleet: a non-public federal register narrows opacity at the point of incorporation even where the register itself is not publicly searchable. The AMLO-FINMA sanctions-circumvention screening requirement and the referendum outcome preserving Federal Council sanctions discretion are both relevant to conflict-finance and state-capture tracking conducted by the World Payments and crypto-focused monitors in this fleet, to the extent Swiss correspondent-banking channels remain a transit point for cross-border flows subject to EU or UN sanctions regimes. #### Outlook The period through the fifth-round FATF mutual evaluation, as scheduled for 2026 to 2027, is the frame against which Switzerland's current activity should be read. The AMLO-FINMA partial revision is expected to take effect on 1 January 2027, ahead of that evaluation, and the TJPG register, now operational, will have had over a year of bedding-in time by the point assessors engage with it. Whether the third national risk assessment's finding of stable exposure persists once the evaluation tests these structures in practice as scheduled is the open question carried into subsequent cycles. 12 Oct 2026 · fim-2026-10-11 #### Lead Signal Switzerland's revised Anti-Money Laundering Act and its companion Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners entered into force on 1 October 2026, establishing the country's first federal beneficial-ownership register. The register sets a 25% ownership-or-control threshold and imposes a new discrepancy-reporting duty on financial intermediaries, with staggered entity-registration deadlines running from 31 December 2026 to 31 March 2027. This closes a structural gap that has sat openly on Switzerland's regulatory record for years, and it arrives ahead of the country's 5th-round FATF mutual evaluation, whose onsite period is possibly scheduled for June 2027 with a possible Plenary discussion in February 2028. Two independent commentary sources corroborate the commencement, though no primary FedLex or Federal Council text was retrieved this cycle, which caps confidence at the probable tier rather than confirmed. #### Other Developments FINMA's proliferation-financing consultation opened on 12 May 2026, proposing a partial revision of the Anti-Money Laundering Ordinance that would amend Articles 1 and 8 to require organisational measures against breaches of coercive measures under the Embargo Act, implementing FATF Recommendations 1 and 2. Entry into force is expected late 2026, though this rests on a single commentary source rather than FINMA's own consultation page. A banking-licence revocation , reported via a secondary aggregator citing a FINMA enforcement notice, saw MBaer Merchant Bank lose its banking licence and face a liquidation order after FINMA found the bank had assisted clients in circumventing official asset freezes; the bank withdrew its appeal on 27 February 2026, allowing the order to take effect. This claim rests on a single tier-four source and has not been independently re-verified at FINMA's own register. The FinIA-reform consultation , covering new payment-instrument and crypto-institution licence categories, closed on 6 February 2026 and remains at proposal stage, with entry into force not expected before 2027, and some commentary citing 2028. #### Cross-Monitor Connections The beneficial-ownership register commencement is structurally relevant to both the crypto and world-payments monitors: crypto-asset operators and payment companies are explicitly named among the affected firm types under the new transparency regime, meaning the KYC and beneficial-ownership architecture that FINMA-supervised banks have long operated under now extends formally to a wider obliged-entity population. The FinIA reform's payment-instrument and crypto-institution licence categories, still at consultation stage, sit at the direct intersection of this AML architecture and the payments monitor's stablecoin tracking, since any future stablecoin issuer licensed under a Payment Instrument Institution category would inherit the same beneficial-ownership and reporting obligations described here. #### Outlook The period to watch runs through the first quarter of 2027, when the staggered beneficial-ownership registration deadlines close and the first discrepancy reports would begin to surface. Separately, FINMA's AMLO-FINMA proliferation-financing amendments, if finalised as proposed, would take effect in late 2026, ahead of the FATF mutual evaluation's possible 2027 onsite visit. Both tracks position Switzerland to enter its FATF review with freshly commenced, rather than long-standing, beneficial-ownership and proliferation-financing architecture, a timing dynamic worth monitoring for how the evaluators weigh newly operative frameworks against their track record at audit. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Switzerland's financial-integrity architecture moved on its own domestic timetable this cycle rather than through a sanctions event. On 1 October 2026 the Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners (TJPG) and the revised Anti-Money Laundering Act (GwG, SR 955.0) entered into force together. The Federal Office of Justice began live operation of the country's first-ever central federal Transparency Register the same day, following a pilot phase that involved roughly 2,500 companies, with the beneficial-ownership threshold set at natural persons controlling more than 25 percent of capital or voting rights. The timing is not incidental: Switzerland's fifth-round FATF mutual evaluation has an on-site period possibly in June 2027 and a plenary discussion possibly in February 2028, and the Federal Council appears to have sequenced commencement of both instruments to allow effectiveness to be demonstrated ahead of that assessment window. Alongside the register, the revised GwG extends the anti-money-laundering perimeter to professional advisers, including lawyers, notaries, fiduciaries, and mergers-and-acquisitions or company-formation advisers, on an activity basis across five trigger categories. This closes a long-flagged enabler-jurisdiction gap, though the specific professional-activity thresholds reported this cycle rest on secondary legal commentary rather than a directly retrieved statutory text, and should be read as probable rather than confirmed pending direct verification against the Fedlex GwG and AMLO provisions. #### Other Developments Sanctions posture holds steady. Switzerland's standing sanctions position remains the Federal Council's implementation of the EU's 20th sanctions package on 19-20 August 2026, under the Ukraine Ordinance framework. No new Switzerland-specific designation was dated within this window, though UN Panel of Experts and OFAC/OFSI Houthi-linked sanctions channels were not actively queried this cycle, so this should be read as a coverage gap rather than a confirmed no-change finding for that sub-channel. Crypto licensing framework remains in consultation. The Financial Institutions Act amendment proposing new Payment Instrument Institution and Crypto-Institution licence categories had its consultation close on 6 February 2026, with entry into force expected not before 2027. No new in-window development moved this file forward this cycle; it remains a pending structural shift that would move affected custody, trading, and stablecoin-issuance firms from self-regulatory-organisation oversight toward direct prudential supervision by FINMA. Structural distinction from the EU framework persists. Switzerland remains a member of the European Free Trade Association but not the European Economic Area, so the EU's AML Regulation, sixth Anti-Money Laundering Directive, and AMLA Regulation carry no transposition obligation into Swiss law. The reforms taking effect this cycle are autonomous national measures assessed directly by FATF rather than EU-driven transposition. #### Cross-Monitor Connections The commencement of Switzerland's beneficial-ownership register and the extension of AML duties to professional advisers intersect with corporate-transparency and enabler-jurisdiction questions that the data-protection monitor also tracks from a different angle, particularly around what information the Transparency Register holds and who may access it. The pending Crypto-Institution licence category is relevant to crypto-monitor coverage of Swiss digital-asset custody and stablecoin-issuance supervision, since it would shift oversight from self-regulatory bodies to direct FINMA prudential supervision. #### Outlook The near-term marker to watch is whether the Federal Council or FINMA issues implementing guidance clarifying the professional-activity thresholds for the adviser AML perimeter, which would move that finding from probable to confirmed. Further out, the FATF fifth-round mutual evaluation, with an on-site period possibly in June 2027 and plenary discussion possibly in February 2028, will test whether the new Transparency Register and adviser-perimeter extension translate into measured effectiveness rather than formal compliance alone. The FinIA licensing reform remains a slower-moving structural item, with entry into force not expected before 2027. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Switzerland is running a coordinated, multi-instrument build-out of its anti-money-laundering architecture ahead of a fifth-round FATF mutual evaluation expected in 2027 or 2028, and this cycle produced three concrete, connected pieces of that build-out. The Transparency of Legal Entities Act (TJPG) has been adopted, with its referendum deadline lapsing unchallenged on 15 January 2026, creating for the first time a federal beneficial-ownership register; both it and a parallel partial revision of the Anti-Money Laundering Act (GwG), which extends the AML obliged-entity perimeter to defined categories of professional advisors, are now expected to enter into force in the second half of 2026. Separately, FINMA has opened a public consultation on a partial revision of its own Anti-Money Laundering Ordinance (AMLO-FINMA), proposing a new Article 9b on understanding ownership and control structures, a new Article 30 elevating sanctions-compliance organisation to a peer obligation alongside AML compliance, and an amended Article 37 addressing payable-through correspondent accounts consistent with FATF Criterion 13.2. That consultation opened 12 May 2026 with a target entry into force of 1 January 2027. Read together, these three instruments target precisely the gaps that FATF evaluators have historically flagged in Switzerland: beneficial-ownership opacity, an under-inclusive professional-advisor perimeter, and correspondent-banking due diligence. The direction of travel is unambiguous even though none of the three has yet taken legal effect. #### Other Developments Sanctions-compliance organisation as a formal duty. The proposed Article 30 of AMLO-FINMA does not merely restate existing sanctions obligations; it formalises embargo and sanctions-compliance organisation as an obligation of equivalent standing to AML compliance itself, a structural tightening specific to Switzerland's own supervisory architecture rather than a response to a particular sanctions-evasion event. Correspondent-account due diligence. The proposed amendment to Article 37 addresses payable-through correspondent accounts, a vector explicitly aligned to FATF Recommendation 13 and its Criterion 13.2, and is aimed at banks and cross-sector obliged entities engaged in correspondent relationships. Structural jurisdictional position. Switzerland's relationship to the EU AML Package (the AML Regulation, the sixth Anti-Money Laundering Directive, and the AMLA Regulation establishing the Anti-Money Laundering Authority) remains one of non-application: Switzerland is a member of EFTA but not the EEA, so the Package does not reach it through EEA Joint Committee incorporation. Switzerland instead runs an autonomous GwG/AMLA-distinct regime, independently assessed by FATF directly rather than folded into an EU-level supervisory perimeter. This structural fact is the durable backdrop against which the domestic build-out described above should be read: Switzerland is strengthening its own architecture rather than transposing an externally-set one. #### Cross-Monitor Connections The TJPG beneficial-ownership register and the GwG advisor-perimeter extension both bear directly on corporate-transparency exposure of the kind tracked across the fleet's other monitors: a federal BO register narrows the space in which opaque corporate and fund structures can be used to obscure beneficial ownership, a vector relevant wherever conflict-finance or sanctions-evasion structures rely on Swiss corporate vehicles. The AMLO-FINMA correspondent-account provisions likewise intersect with payment-infrastructure monitoring of correspondent-banking access and settlement risk, since payable-through account arrangements sit at the center of both AML and payments-system oversight. No cross-border sanctions-evasion or conflict-finance development specific to Switzerland was identified this cycle; the connections here are architectural rather than event-driven. #### Outlook The key date to watch is the second half of 2026, when both the TJPG beneficial-ownership register and the GwG advisor-perimeter extension are expected to take effect, following the implementing ordinance (TJPV) consultation that ran through 30 January 2026. The AMLO-FINMA consultation outcome, targeting 1 January 2027, is the next major date after that. Both should be read as deliberate preparation for Switzerland's fifth-round FATF mutual evaluation, expected in 2027 or 2028; the extent to which these instruments are judged adequate by FATF evaluators once in force will be the next material signal for Switzerland's AML/CTF standing. 21 Sep 2026 · fim-2026-08-05 #### Lead Signal Switzerland moved on two structurally significant AML fronts this cycle. The Federal Council confirmed on 12 June 2026 a firm 1 October 2026 entry-into-force date for the Legal Entities Transparency Act (LETA) and the revised Anti-Money Laundering Act (AMLA), replacing a previously softer second-half-2026 estimate and bringing an estimated 500,000 to 600,000 in-scope entities under centralised, EasyGov-based reporting for the first time (assessed; Tier-4 corroboration only, no Tier-1/2 primary source retrieved this cycle). In parallel, the Federal Council completed implementation of the remainder of the EU 19th sanctions package on 26 February 2026 and partially implemented the 20th package on 22 May 2026, introducing the first dedicated Swiss crypto-asset sanctions framework: a ban on ruble-backed stablecoins, RUBx, and digital-rouble transactions, alongside extended transaction bans against twenty Russian banks (assessed; two Tier-3 legal-sector sources, no Tier-1 SECO anchor retrieved this cycle). Read together, these are not two unrelated compliance-calendar items. Both show Switzerland front-loading structural AML and sanctions architecture ahead of the 2027-2028 FATF mutual evaluation: a beneficial-ownership register replacing self-attestation, and a sanctions perimeter extended into a previously under-instrumented crypto-denominated evasion channel. This is the architecture-over-incident lead signal for the cycle: a jurisdiction demonstrably building out its compliance record on a fixed evaluation clock, rather than responding to a single enforcement incident. #### Other Developments Mexico cartel fuel-theft network drew coordinated federal action. FinCEN issued a supplemental alert in June 2026 on fiscal fuel-smuggling and tax-evasion schemes linked to CJNG, coordinated with the OFAC designation of two Mexican nationals and nine entities (high confidence; Tier-1 FinCEN primary source). A separate Tier-3 source describes FinCEN advising banks to scrutinise Chinese-owned United States firms receiving export funds without corresponding inventory, characterising a mutualistic Mexican-cartel and Chinese-network trade-based-money-laundering relationship spanning US-Mexico-China-Hong Kong-UAE corridors (assessed; single source, not independently retrieved). FINMA opened a consultation tightening the professional-intermediary perimeter. The draft AMLO revision would require identification of the natural person behind complex ownership structures and enhance senior-management accountability, while press reporting describes intensifying enforcement attention toward smaller private banks, naming CIM, Reyl, CBH and Mirabaud (assessed; Tier-3/4 sources only, no FINMA primary consultation page retrieved this cycle). A parallel Swiss licensing reform would formalise crypto-asset and payment-instrument business. A draft bill, consultation closed February 2026, proposes replacing the Article 1b fintech licence with new payment instrument institution and crypto institution categories, removing the current CHF 100 million client-fund cap; entry into force is expected 2027 at the earliest (assessed; two Tier-4 sources, no Tier-1/2 primary anchor). Enabler-jurisdiction risk persisted at varying intensity outside Switzerland. The Golden Triangle Special Economic Zone in Laos, the Kings Romans/Zhao Wei network, continues functioning as an entrenched laundering and scam-compound hub despite 2018 US sanctions (assessed; single Tier-2 source). Cambodia intensified enforcement against illegal online-gambling and scam centres in January 2026 specifically to avoid a third FATF grey-list placement (assessed; Tier-3 source). Colombia was designated by the US State Department in its FY2026 presidential determination as having failed demonstrably to meet counternarcotics obligations, the first such finding in nearly thirty years (high confidence; Tier-1 US State Department source). #### Cross-Monitor Connections The Mexico fuel-theft finding routes directly to conflict-finance and extractive-industry monitoring: fuel and energy-product import dependency is being exploited as a revenue-generation mechanism in a manner structurally similar to resource-flow diversion financing models tracked elsewhere. The Chinese-network trade-based-money-laundering advisory, if corroborated, would route to enabler-jurisdiction and trade-corridor monitoring given its US-Mexico-China-Hong Kong-UAE routing description. The Swiss crypto-asset sanctions and licensing-reform developments carry payments-monitor relevance: a jurisdiction simultaneously restricting sanctioned crypto-asset flows and formalising a licensed channel for crypto-asset and payment-instrument business is a posture payments-focused monitoring should track alongside this AML-focused read. #### Outlook The Swiss FATF 2027-2028 evaluation window is the structural clock against which the LETA/AMLA October 2026 date, the AMLO consultation, and the FinIA licensing reform should all be read. Expect continued front-loading of AML and sanctions architecture in Switzerland through that window, with the sanctions-regime divergence tracker (mixed trajectory, given Switzerland declined to list seven third-country companies in the 20th package) as the item most likely to generate near-term friction with the EU baseline. On the Mexico corridor, watch for further OFAC designations building on the CJNG fuel-theft finding, and for whether the Chinese-network TBML advisory is independently corroborated at Tier-1 or Tier-2. Domain intelligence (D1–D8) #### Sanctions Switzerland's sanctions-compliance architecture gained an explicit statutory hook this cycle. Since 1 October 2026, Article 8 of the Anti-Money Laundering Act itself requires financial intermediaries to take the organisational measures needed to prevent breaches of coercive measures under the Embargo Act. This is a codification rather than a wholesale new obligation: Swiss financial intermediaries have long been subject to sanctions-screening expectations through SECO ordinances and FINMA guidance, but folding the organisational duty directly into the AML statute gives supervisors a clearer, statute-level basis for enforcement action against firms that fail to maintain adequate screening, risk-analysis, and instruction frameworks against sanctions breaches. Continue reading The confidence attached to this development is probable rather than confirmed. The material retrieved this cycle consists of third-party legal commentary describing the amendment's effect; the Federal Council's or FINMA's own primary ordinance text implementing the change was not directly retrieved. This matters because the precise scope of what counts as adequate organisational measures, and how FINMA proposes to supervise compliance with the new Article 8 duty in practice, cannot yet be stated with full confidence. What can be said is that Switzerland continues to apply UN sanctions and, on a case-by-case basis, EU sanctions measures autonomously through SECO under the Embargo Act, rather than through automatic incorporation of EU sanctions lists; the Article 8 amendment reinforces the domestic enforcement architecture behind that autonomous posture without changing its substantive independence from EU listings. The practical significance of this codification lies less in creating a new category of prohibited conduct and more in giving FINMA an unambiguous statutory peg for enforcement against firms whose sanctions-compliance organisation is deficient. Previously, a firm's failure to maintain adequate internal controls against sanctions breaches might have been addressed through general AML supervisory powers or through SECO's own enforcement channel under the Embargo Act; locating the organisational duty explicitly in Article 8 of the AMLA itself streamlines that enforcement path and makes it harder for a firm to argue that sanctions-organisation failures fall outside FINMA's direct AML supervisory remit. This development should be read alongside the jurisdiction's broader autonomous sanctions posture. Switzerland is not an EU member and does not mechanically transpose the EU's sanctions list; it implements UN sanctions directly and applies EU measures selectively via its own ordinances. The Article 8 codification does not alter this architecture, but it does narrow the gap between the formal international expectation that financial intermediaries organise themselves against sanctions breaches and the explicit domestic statutory language requiring them to do so. #### Outlook The principal outstanding item is direct verification of the Federal Council's or FINMA's own text implementing the Article 8 amendment, which would allow confidence in this development to move from probable to confirmed and would clarify the precise organisational-measures standard being imposed. Separately, the jurisdiction's fifth-round FATF mutual evaluation, with a possible onsite assessment period from June 2027 and a possible plenary discussion in February 2028, gives a concrete horizon against which Switzerland's sanctions-organisation duty and its autonomous implementation architecture will likely be tested by international assessors. Firms operating in or through Switzerland should expect FINMA's supervisory attention to the adequacy of sanctions-screening and organisational controls to increase in the period leading into that evaluation window, as scheduled. #### Beneficial Ownership and Corporate Transparency Switzerland sits outside the European Union and the European Economic Area, so the EU Anti-Money Laundering 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, does not reach Switzerland through Joint Committee incorporation and is not the primary subject matter for assessing the Swiss beneficial-ownership regime. Globally, the EU Package sets the structural direction for how supervision shifts from purely national authorities toward a hybrid EU-level regime; in Switzerland, the directly relevant development this cycle is domestic rather than European, and is also structural rather than incident-driven. Continue reading On 1 October 2026, the Transparency of Legal Entities Act (TJPG) and the revised Anti-Money Laundering Act (GwG, SR 955.0) both entered into force. Together they create Switzerland's first federal register of beneficial owners, administered by the Federal Office of Justice and non-public in character, and they extend GwG due-diligence duties to a defined population of advisors who previously sat outside the regime's scope, with an exclusion preserved for lawyers and notaries acting within judicial, administrative or arbitration proceedings. Existing legal entities face staggered first-filing deadlines running from three months up to two years depending on entity form, while advisors newly brought within scope have six months from the entry-into-force date to apply for membership of a recognised self-regulatory organisation. The architectural significance of this change is that it replaces a purely contractual, intermediary-held model of beneficial-ownership identification with a federally-held record, even though that record is not publicly searchable. A non-public register changes who can query beneficial-ownership data and under what authority, which is a materially different transparency proposition from the publicly accessible registers some other jurisdictions maintain, even where the underlying identification obligations on obliged entities are comparably rigorous. The advisor-perimeter extension is the more targeted move: it closes a gap in coverage that enabler-jurisdiction commentary had previously identified, bringing a defined category of professional facilitators who were not previously obliged entities into the due-diligence regime for the first time. Both changes commenced on the same date and should be read as a single coordinated tightening of the architecture around who identifies beneficial owners and who is recorded as holding that status, rather than as two independent reforms. #### Outlook The register and the widened advisor perimeter are now in force and the near-term question is one of implementation rather than further legislative change: whether staggered filing deadlines are met across entity forms, and whether the newly-captured advisor population completes self-regulatory-organisation enrolment within the six-month window. No further beneficial-ownership-specific legislative step was reported as scheduled this cycle, and Switzerland's remaining architecture questions in this area are more likely to surface through the FATF's fifth-round mutual evaluation, for which an onsite visit is scheduled around mid-2027, than through any further domestic statutory change in the near term. #### Enabler Jurisdictions and Professional Facilitators Switzerland's standing as an enabler jurisdiction rests heavily on the perimeter of who the anti-money-laundering regime actually captures as an obliged entity, since gaps in that perimeter are where professional facilitators have historically operated with less friction than banks and other core financial intermediaries. This cycle the perimeter moved. The revised Anti-Money Laundering Act (GwG, SR 955.0), in force since 1 October 2026 alongside the new Transparency of Legal Entities Act, extends due-diligence duties to a defined set of advisors who previously sat outside the regime. The Act preserves an exclusion for lawyers and notaries acting within the scope of judicial, administrative or arbitration proceedings, but captures advisory activity outside that carve-out for the first time. Continue reading Read through an enabler-jurisdiction lens, this is a gap-closing move rather than a response to any single enforcement episode: it is the kind of structural adjustment that matters more than an individual case because it changes the population of actors subject to ongoing due-diligence duty, not just the outcome of one transaction or one client relationship. No CH-specific enforcement action against a professional facilitator was identified this cycle, and no distinct enabler-jurisdiction development beyond the advisor-perimeter expansion itself was located. The absence of an enforcement signal here is not itself informative in either direction; it simply means the development to weigh this cycle is the legislative one. The newly-captured advisors have six months from the 1 October 2026 entry-into-force date to apply to a recognised self-regulatory organisation, which is the operative mechanism through which Switzerland's decentralised, SRO-based supervisory model will actually extend oversight to this population. Until that enrolment process plays out, the practical reach of the expanded perimeter is a matter of registration rather than demonstrated compliance behaviour, and the architecture-over-incident framing that applies to this domain generally applies with particular force here: the legal change is real and dated, but its effect on actual facilitator conduct will only become visible in later cycles. #### Outlook The immediate marker to watch is whether the newly-captured advisor population completes self-regulatory-organisation enrolment within its six-month window following the 1 October 2026 commencement date, which would fall around April 2027. Beyond that, Switzerland's enabler-jurisdiction standing is likely to be tested most directly by the FATF's fifth-round mutual evaluation, with a possible onsite visit scheduled around mid-2027; that evaluation is the most plausible venue for an authoritative external assessment of whether the widened advisor perimeter has closed the gap it was designed to close. No further enabler-jurisdiction-specific legislative step was reported as scheduled this cycle. #### Conflict Finance and Extractive-Industry Integrity Signal in this domain for Switzerland this cycle is comparatively thin relative to the D1, D2, and D3 developments carried above, and is confined to a single enforcement episode and a standing structural assessment rather than new developments. The September 2025 raid on the Zug office of metals trader Open Mineral AG, conducted by SECO and the Office of the Attorney General as part of a sanctions-breach investigation into Russian gold trading, remains the only concrete enforcement action in this domain, and no public outcome has been disclosed as of this cycle. Traced through the F4 conflict-finance framework, source, channel, and deployment, the underlying structural assessment holds that Russian-origin gold and oil extraction constitutes the source, Swiss and UAE trading-house layering the channel, and Russian war-economy revenue the deployment; the Geneva and Zug commodity-trading hub, comprising tens of thousands of registered entities, remains the structural conduit risk, and the Open Mineral action, targeting a single house, does not alter that broader structural exposure. No Sahel or Democratic Republic of Congo extractive-industry linkage was established for Switzerland this cycle, and the interpreter research coverage explicitly flags D4 coverage for this jurisdiction as thin in the current pass. The honest position for this cycle is that the conflict-finance conduit risk is a standing, not newly-evidenced, feature of the Swiss commodity-trading architecture, carried forward from the prior baseline rather than freshly demonstrated this cycle. Continue reading #### Outlook The outstanding question for this domain is whether the Open Mineral AG investigation produces any public enforcement outcome that would test the reach of Swiss authorities beyond a single trading house into the broader commodity-conduit architecture; none has been disclosed as of this cycle. Given the acknowledged thinness of this cycle coverage, subsequent cycles should be read for whether additional evidence narrows or confirms the standing conflict-finance conduit assessment for the Geneva and Zug hub. #### Crypto, Digital Assets, and Financial Innovation Switzerland's own digital-asset regulatory architecture, not the European Union's Markets in Crypto-Assets framework or FATF's virtual-asset standards, is the directly relevant backdrop for this cycle's development, and FINMA's own supervisory action is the lead story. On 20 October 2026, FINMA approved Switzerland's first retail Bitcoin exchange-traded fund. The approval applied FINMA's crypto-custody guidance issued earlier in the year as the operational template for the product, and FINMA granted an exemption from the standard fund risk-diversification rules that would otherwise have constrained a single-asset product of this kind. Continue reading This is an episodic regulatory-approval event rather than a change to Switzerland's standing legal framework for digital assets, and it should be read that way: no statute or ordinance changed as a result of this approval. Its significance is that it is the first time FINMA's January 2026 custody guidance has been applied as working precedent to a retail-accessible, exchange-traded product, which signals that the custody framework issued earlier in the year is now operationally load-bearing rather than merely aspirational guidance sitting unused. A retail-accessible, FINMA-supervised wrapper around Bitcoin changes the on-ramp available to both institutional and retail money relative to direct token holding, and that shift in accessible structure is itself a form of signal independent of any change in the underlying legal perimeter. Separately, and still pending rather than in force, a Federal Council and State Secretariat for International Finance proposal would replace the 2018 FinTech licence with a dedicated payment-instrument-institution licence, removing its CHF 100 million deposit cap, and would create a route for issuing what the proposal terms Stable Payment Crypto-Assets, alongside a separate crypto-institution licence covering custody and trading services. As matters stand, Switzerland has no dedicated stablecoin-issuer or crypto-institution licence, and issuers currently rely on bank-guarantee structures to operate pending this reform. The proposal remains at consultation stage with an expected timeline in early 2027, so as scheduled rather than confirmed. #### Outlook The Bitcoin ETF approval is likely to be read by the market as confirmation that FINMA's custody guidance is a workable basis for further retail digital-asset product approvals, which may increase the volume of similar applications in subsequent cycles. The more structurally significant item to track, however, is the pending FinIA amendment creating payment-instrument-institution and crypto-institution licences and the Stable Payment Crypto-Asset regime: if it proceeds on its stated early-2027 timeline, it would close the current licensing gap that forces stablecoin issuers into bank-guarantee workarounds. Until that proposal moves past consultation, Switzerland's dedicated crypto-licensing architecture remains incomplete even as its product-approval practice, illustrated by the Bitcoin ETF, continues to develop. #### Compliance Technology and Active Defence Two developments define this domain for Switzerland this cycle, and both concern the balance between supervisory capability and technological risk rather than any single enforcement action. First, the Federal Council formally tabled a dispatch on the revision of the Banking Act on 22 April 2026, granting FINMA direct fining powers; the bill is now before Parliament and has not yet been enacted. This addresses a supervisory capacity deficit widely identified as a contributing factor in the supervisory failure preceding the 2023 collapse of Credit Suisse, since FINMA currently has no statutory power to directly fine regulated entities or compel disclosure of enforcement decisions in the way many peer supervisors can. This corrects an earlier soft-flagged assessment that had treated the June 2025 proposal as an unadvanced policy intention; it has since progressed to a formal parliamentary dispatch, though the gap remains partially, not fully, addressed pending enactment and there is no established parliamentary passage timeline. Continue reading Second, and separately, FINMA stated in April 2026 that immediate, unrestricted bank access to advanced AI models would pose systemic risk to Swiss banks. This is an early and notable instance of a financial supervisor articulating AI-governance risk directly and proactively, rather than reactively following an AI-related incident, and it situates Switzerland among the first jurisdictions in this monitor coverage to have a supervisor take a public position on the systemic-risk dimension of unrestricted advanced-AI access within regulated financial institutions. Read together with the fining-power reform, these two developments describe a supervisor, FINMA, that is simultaneously seeking expanded enforcement capability over traditional compliance failures and articulating a forward-looking caution about a still-emerging technology-governance risk, a combination that is analytically significant for how compliance-technology and active-defence capability is likely to evolve in Switzerland relative to jurisdictions where supervisors have been slower to address either dimension. #### Outlook The parliamentary timeline for the FINMA fining-power Banking Act revision is not yet established, and this remains the clearest structural marker to track: enactment would represent a genuine capability upgrade, but the gap identified by the Credit Suisse episode remains only partially addressed while the bill sits before Parliament. FINMA articulated AI-governance stance also invites tracking of whether it is followed by concrete supervisory guidance or rulemaking on advanced-AI access within regulated institutions, or whether it remains, for now, a statement of concern without an accompanying regulatory instrument. #### AML/CTF Regime The lead development in Switzerland's AML/CTF regime this cycle is the partial revision of FINMA Circular 2016/7 on video and online identification, which enters into force on 1 November 2026. The revision admits the Swiss e-ID as a valid basis for online identification, treats QR-coded identity documents as equivalent to machine-readable-zone documents for identification purposes, and adds a liveness-detection requirement that FINMA explicitly frames as a response to the risk of AI-driven impersonation in remote onboarding. This sits alongside, and is functionally connected to, the 1 October 2026 entry into force of the revised Anti-Money Laundering Act (GwG, SR 955.0) and the new Transparency of Legal Entities Act, which together extended customer due-diligence duties to a defined set of advisors and created Switzerland's first federal beneficial-ownership register. Continue reading The two developments should be read together rather than as separate items: the GwG and TJPG changes determine who must perform customer and beneficial-owner identification and what is captured as a result, while the Circular 2016/7 revision determines how that identification is technically performed for remote and online relationships. Firms whose onboarding processes still rely solely on legacy machine-readable-zone or chip-read document verification will need to assess how integration of the Swiss e-ID and the new liveness-detection requirement map onto the baseline the revised Circular sets, ahead of its 1 November 2026 commencement date. The three-pillar balance that AML/CTF analysis should maintain across money laundering, counter-terrorist financing and counter-proliferation financing is worth stating explicitly here: all three of this cycle's structural changes, the advisor-perimeter extension, the beneficial-ownership register, and the identification-standard revision, are anti-money-laundering-architecture measures in their immediate framing. No CTF-specific or CPF-specific development was identified for Switzerland this cycle, and that absence should be noted rather than silently carried over, since AML enforcement volume can otherwise crowd out visibility of CTF and CPF signal even where none in fact occurred. The combination of a widened due-diligence perimeter, a new beneficial-ownership record, and a modernised identification standard represents a coordinated tightening of the compliance architecture obliged entities operate within, commencing within the same four-week window. None of the three changes was driven by a single enforcement action; all three are legislative or supervisory-guidance measures taking effect on pre-announced dates, which is consistent with the architecture-over-incident framing that this regime's recent history generally supports. #### Outlook The most immediate marker is the 1 November 2026 commencement of the revised Circular 2016/7, after which firms relying on legacy identification-only onboarding will be operating against an outdated baseline. Looking further out, a partial revision of the Anti-Money Laundering Ordinance (AMLO-FINMA), intended to embed Embargo Act coercive-measures compliance as an organisational duty for obliged entities, had its consultation close in June 2026 and is planned, as scheduled, to take effect on 1 January 2027; the final text had not been reported as at this cycle. Switzerland's fifth-round FATF mutual evaluation, with a possible onsite visit around mid-2027, is the most likely venue for an authoritative external assessment of how this cycle's combined architecture changes are regarded. #### Commercial Activity The defining commercial event of the cycle is FINMA's approval, on 20 October 2026, of Switzerland's first retail Bitcoin exchange-traded fund, issued by BIT Asset Management AG. Read as a commercial product event, it is notable less for its novelty as a crypto product and more for the regulatory mechanism used to clear it: an exemption from the standard fund risk-diversification rules that would otherwise constrain a single-asset fund, justified by reference to Bitcoin's trading history and liquidity, and paired with custody safeguards drawn from FINMA's own guidance issued in January 2026. The transaction itself carries no disclosed financial amount, consistent with its character as a regulatory product-approval event rather than a financing or acquisition transaction, and it was cleared through a sector-licensing review process at FINMA rather than a bespoke legislative or statutory gateway. Continue reading The approval sits inside a wider pattern of commercial and regulatory-technology-adjacent activity in the Swiss market touching anti-money-laundering compliance this cycle, even though the retail Bitcoin product itself is a digital-asset investment vehicle rather than a compliance-technology product. The product's custody-safeguard conditions function, in effect, as a compliance-control requirement attached to a commercial launch: the fund cannot operate without satisfying the custody template FINMA set out separately, which means the commercial viability of the product and the firm's compliance posture are now directly coupled by regulatory design. No other disclosed commercial transaction, acquisition or product launch touching the anti-money-laundering, sanctions or beneficial-ownership space in Switzerland reached a comparable threshold of materiality this cycle. The absence of comparable commercial activity elsewhere in the market is consistent with a period in which the structural and legislative changes, namely the beneficial-ownership register and the advisor-perimeter expansion, have drawn firms' compliance resources and management attention toward implementation rather than toward new product or transactional activity. #### Outlook The relevant question going forward is whether the exemption-based pathway FINMA used to approve the Bitcoin exchange-traded fund becomes a repeatable commercial template for other single-asset digital-asset products, or remains a one-off accommodation. Firms considering similar product launches in the Swiss market will likely look to the custody-safeguard conditions attached to this approval as the de facto standard pending any further commercial or licensing developments, including the separate Financial Institutions Act reform that remains at a pre-dispatch stage with a wide uncertainty band pointed toward roughly the first quarter of 2027. Regulatory horizon Adopted 2026-Q4 · ±half_year ### TJPG BO register + GwG advisor-perimeter extension Creation of a federal beneficial-ownership register (TJPG) and extension of GwG obliged-entity scope to defined professional advisors. [Swiss Federal Assembly / Federal Council Source](https://bollwerk.ai/blog/swiss-aml-revision-2026/) Post Consultation 2027 · ±year ### Swiss FinIA payment/crypto licence reform (consultation closed Feb 2026; entry into force expected 2027 at the earliest) Consultation closed February 2026; new licence categories expected to replace the fintech licence. [Source](https://fintechwerkstatt.ch/swiss-fintech-licence-finma-approval/swiss-payment-institution-licence/) Consultation 1 Jan 2027 · ±quarter ### GwV-FINMA partial revision on pass-through accounts Pass-through accounts offered under correspondent banking could only be used to execute payments for the counterparty's customers if the counterparty supplies relevant customer due-diligence information on request. [FINMA Source](https://www.bdo.ch/de-ch/publikationen/finma-eroffnet-anhorung-zur-teilrevision-der-geldwaschereiverordnung-finma) Adopted 1 Jan 2027 · ±quarter ### AMLO-FINMA partial revision (Embargo Act coercive-measures compliance) planned entry into force Revised AMLO-FINMA provisions on Embargo Act coercive-measures compliance architecture enter into force. [Source](https://www.lexology.com/library/detail.aspx?g=6d80f938-5ec5-402c-be97-05fbf38efddd) Consultation 2027-Q1 · ±year ### FinIA amendment: payment instrument institution and crypto institution licences, Stable Payment Crypto-Asset regime A new payment-instrument-institution licence (replacing the 2018 FinTech licence, removing its CHF 100m deposit cap) permitting issuance of Stable Payment Crypto-Assets, plus a separate crypto-institution licence for custody/trading services. [Source](https://www.admin.ch/en/newnsb/x4TMWQ1SWofNoFx7XyHhY) 5 dated · 3 pending date · baseline fim-2026-07-08 Role action cards MLRO ### Swiss onboarding identification standards and the advisor-due-diligence perimeter both moved this cycle. The GwG and TJPG entry into force on 1 October 2026 widens the population of advisors subject to customer and beneficial-owner due-diligence duties, while the Circular 2016/7 revision taking effect 1 November 2026 changes what counts as an acceptable identification method, including Swiss e-ID and QR-coded documents, and adds liveness detection against AI impersonation. 2 evidence refs Compliance ### Two structural instruments entered into force within a four-week window, extending scope and modernising identification standards. The advisor-perimeter extension and the new federal beneficial-ownership register under the GwG and TJPG took effect 1 October 2026, and the revised Circular 2016/7 identification standard takes effect 1 November 2026; firms with legacy onboarding processes or advisory activity newly within scope face a compressed compliance-framework update window. 2 evidence refs Legal ### No new enforcement action was identified this cycle; the movement is legislative and supervisory-guidance based. The TJPG, revised GwG, and Circular 2016/7 revision are all legislative or guidance instruments with pre-announced commencement dates rather than enforcement outcomes, and the lawyer and notary exclusion from the widened advisor perimeter is limited to activity within judicial, administrative or arbitration proceedings. 1 evidence refs Board ### Switzerland tightened its beneficial-ownership and onboarding architecture without any accompanying enforcement or grey-list event. The entry into force of a federal, non-public beneficial-ownership register and a widened advisor due-diligence perimeter, alongside FINMA's approval of the first retail Bitcoin exchange-traded fund, together signal a period of structural compliance-architecture development rather than elevated enforcement or reputational risk this cycle. 2 evidence refs CTO ### FINMA's revised identification circular changes accepted onboarding technology and explicitly targets AI-driven impersonation. From 1 November 2026, Swiss e-ID and QR-coded documents become acceptable identification inputs and a liveness-detection requirement is added; systems relying solely on legacy machine-readable-zone or chip-read verification will need review against this baseline, and FINMA's approval of a retail Bitcoin ETF applying its custody guidance as precedent is relevant to any crypto-custody-adjacent infrastructure. 2 evidence refs Risk ### Three structural changes landed within one cycle: beneficial-ownership registration, advisor-perimeter scope, and onboarding identification standards. Each is a structural rather than episodic development, and together they reduce ambiguity in who is an obliged entity and how identification is performed, while the Bitcoin ETF approval signals FINMA is prepared to apply existing custody guidance as precedent for new retail product structures. 3 evidence refs Operations ### Onboarding workflows face a 1 November 2026 identification-standard change alongside a wider advisor due-diligence population from 1 October 2026. Screening and onboarding workflows need to accommodate Swiss e-ID and QR-coded document acceptance plus liveness detection from 1 November 2026, while newly-captured advisors have six months from 1 October 2026 to enrol with a recognised self-regulatory organisation. 2 evidence refs Audit ### Two in-force structural changes and one pending FINMA product approval create new control-testing scope. Audit trails for identification methods will need to reflect the Circular 2016/7 revision from 1 November 2026, beneficial-ownership filings against the TJPG register's staggered deadlines, and advisor self-regulatory-organisation enrolment records for the newly-captured population, while the Bitcoin ETF approval raises a distinct documentation question around the risk-diversification exemption FINMA granted. 3 evidence refs Scenario sketches ### Advisor-perimeter enrolment lag An illustrative scenario: a segment of the newly-captured advisor population under the revised Anti-Money Laundering Act does not complete self-regulatory-organisation enrolment within the six-month window following the 1 October 2026 commencement date. In this illustrative sketch, the gap between legal capture and actual supervisory enrolment becomes the practical boundary of the widened perimeter for a period, rather than the statutory text itself. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material development this cycle. T2 · EU AML Package / AMLA no_change Switzerland is not EU/EEA; AMLR/6AMLD/AMLA do not reach it via Joint Committee incorporation. Not applicable in regime. T3 · FATF Grey List no_change Switzerland is not on the FATF grey list; fifth-round mutual evaluation scheduled with possible onsite around mid-2027. T4 · Beneficial-Ownership Register Status improving Switzerland's first federal, non-public BO register (TJPG) is now operative since 1 October 2026. T5 · Crypto / VASP Regulatory Framework material_change FINMA approved Switzerland's first retail Bitcoin ETF on 20 October 2026, applying its January 2026 custody guidance; FinIA stablecoin/crypto-institution reform remains at consultation-closed, pre-dispatch status. T6 · Sanctions Regime Divergence no_change No new EU/US/UK/CH autonomous-listing divergence event this cycle; AMLO-FINMA revision remains pre-force (planned 1 January 2027). Registers ### Enforcement actions - 10 Apr 2025 - 2 Apr 2025 - 16 Sep 2025 - 2 Apr 2026 - 1 Jul 2025 - 10 Apr 2025 - 2 Apr 2025 - 16 Sep 2025 - 26 Feb 2026 - 2 Apr 2026 - 22 Oct 2025 - 6 Mar 2026 - 30 Sep 2026 - FINMA inspected Bank Reyl in summer 2023 and escalated inquiries to its enforcement division by January 2024 over AML weaknesses and handling of high-risk PEP-linked accounts, including a former Russian minister and associates of Uzbek and Azerbaijani ruling families. 10 Apr 2025 - Following a SECO probe, the Office of the Attorney General launched a criminal investigation into potential sanctions violations and money laundering, temporarily freezing CHF 1.65 billion in assets, with CHF 60 million later released after failing to meet the legal freezing threshold. 2 Apr 2025 - Swiss authorities raided the Zug office of metals trader Open Mineral AG as part of an investigation into potential sanctions breaches relating to Russian gold trading. 16 Sep 2025 - Swiss prosecutors opened a preliminary probe into MBaer Merchant Bank after it was forced to shut down following US authorities' allegations that it facilitated international money laundering linked to Iran. 2 Apr 2026 - FINMA told Switzerland's largest consumer trading platform, Swissquote, in an annual assessment letter to reduce the volume of suspicious activity reports it was submitting to the country's money-laundering reporting office. 1 Jul 2025 ### Sanctions changes - 12 Aug 2025 - 22 May 2026 - 12 Aug 2025 - 22 May 2026 - 16 May 2025 - 30 Jun 2026 - Switzerland adopted further Russia sanctions aligned with the EU's 18th sanctions package, extending restrictions via SECO ordinance amendments. 12 Aug 2025 - Switzerland adopted most elements of the EU's 20th sanctions package against Russia and Belarus, targeting energy, third-country banks and crypto providers, but declined to adopt certain elements. 22 May 2026 - OFAC published a Memorandum of Understanding with Switzerland's State Secretariat for Economic Affairs (SECO) formalising bilateral cooperation on sanctions implementation and enforcement. 16 May 2025 - SECO reported that Russian assets frozen in Switzerland rose to CHF 7.4 billion (a 28% year-on-year increase), including CHF 7.45 billion in Russian central bank reserves, as Switzerland continued incorporating additional EU-aligned Russia designations. 1 Apr 2025 ### Regulatory horizon (register) - National Risk Assessment refresh cycle (UK HMT NRA, EU SNRA, US FinCEN NRA) - Legal Entities Transparency Act (LETA) / revised AMLA enters into force - Swiss FinIA payment/crypto licence reform (consultation closed Feb 2026; entry into force expected 2027 at the earliest) - UK ECCTA 2023 failure-to-prevent-fraud offence - National Risk Assessment refresh cycle (UK HMT NRA, EU SNRA, US FinCEN NRA) - AMLO-FINMA partial revision (Art. 9b, 30, 37) - TJPG BO register + GwG advisor-perimeter extension - FinIA Payment Instrument Institution / Crypto-Institution licence categories - FATF 5th-round mutual evaluation of Switzerland - AMLO-FINMA partial revision entry into force - FinIA amendment for payment-instrument and crypto institution licences (incl. stablecoin issuance) - Switzerland fifth-round FATF mutual evaluation - Swiss cross-border automatic crypto tax data exchange (CARF) delayed to 2027 - GwV-FINMA partial revision on pass-through accounts - FINMA Circular 2016/7 partial revision in force - FinIA amendment: payment instrument institution and crypto institution licences, Stable Payment Crypto-Asset regime - AMLO-FINMA partial revision (Embargo Act coercive-measures compliance) planned entry into force - FINMA bank-fining power legislative reform - Federal beneficial-ownership transparency register bill - Financial Institutions Act amendment for crypto/DLT market structure - FATF biennial follow-up update on partially-compliant recommendations ### Active schemes - [HIGH] Geneva/Zug commodity-trading conduits for Russian gold and oil - [HIGH] Swiss lawyer/fiduciary network handling Russian shell-company cash flow - Beneficial-ownership opacity via Swiss shell-company registrations — legislative gap narrowing - [HIGH] PEP/oligarch private-banking structuring via secrecy-protected accounts - Stablecoin default-guarantee structuring bypassing direct FINMA licensing Sources - [Swiss Parliament | OCCRP](https://www.occrp.org/en/organizations/swiss-parliament) - [Baer Karrer](https://www.baerkarrer.ch/en/publications/swiss-companies-must-report-their-beneficial-owners-to-a-new-transparency-register-starting-october-2026) - [Lenz Staehelin](https://www.lenzstaehelin.com/news-and-insights/browse-thought-leadership-insights/insights-detail/introduction-of-a-federal-register-of-beneficial-owners/) - [US Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0408) - [FINMA](https://www.finma.ch/en/news/2026/04/20260422-mm-finma-botschaft-br-tbtf/) - [Finews](https://www.finews.com/news/english-news/71195-finma-swiss-financial-markets-supervisory-authority-enforcement-procedures-private-banks) - [https://www.sif.admin.ch/en/anti-money-laundering-act-amla](https://www.sif.admin.ch/en/anti-money-laundering-act-amla) - [https://www.lenzstaehelin.com/news-and-insights/browse-thought-leadership-insights/insights-detail/swiss-sanctions-against-russia-further-alignment-with-the-eu-implementation-of-the-19th-sanctions-package/](https://www.lenzstaehelin.com/news-and-insights/browse-thought-leadership-insights/insights-detail/swiss-sanctions-against-russia-further-alignment-with-the-eu-implementation-of-the-19th-sanctions-package/) - [https://www.seco.admin.ch/en/newnsb/Byvj7-WGL93MiOgIL-f2p](https://www.seco.admin.ch/en/newnsb/Byvj7-WGL93MiOgIL-f2p) - [https://sanctionsnews.bakermckenzie.com/switzerland-implements-remainder-of-eus-19th-sanctions-package-against-russia/](https://sanctionsnews.bakermckenzie.com/switzerland-implements-remainder-of-eus-19th-sanctions-package-against-russia/) - [https://www.grantthornton.ch/en/insights/switzerland-crypto-sanctions-russia/](https://www.grantthornton.ch/en/insights/switzerland-crypto-sanctions-russia/) - [https://www.loyensloeff.com/insights/news--events/news/swiss-federal-council-proposes-finia-amendments-new-licences-for-payment-and-crypto-institutions-to-replace-fintech-regime/](https://www.loyensloeff.com/insights/news--events/news/swiss-federal-council-proposes-finia-amendments-new-licences-for-payment-and-crypto-institutions-to-replace-fintech-regime/) - [https://globallawexperts.com/swiss-beneficial-ownership-register-2026/](https://globallawexperts.com/swiss-beneficial-ownership-register-2026/) - [https://fincrimecentral.com/switzerland-finma-2026-aml-ordinance-revisions/](https://fincrimecentral.com/switzerland-finma-2026-aml-ordinance-revisions/) - [https://fintechwerkstatt.ch/swiss-fintech-licence-finma-approval/swiss-payment-institution-licence/](https://fintechwerkstatt.ch/swiss-fintech-licence-finma-approval/swiss-payment-institution-licence/) - [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [https://www.gtreview.com/news/americas/us-fires-warning-over-mexican-cartels-chinese-money-laundering-networks/](https://www.gtreview.com/news/americas/us-fires-warning-over-mexican-cartels-chinese-money-laundering-networks/) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/](https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/) - [https://www.state.gov/releases/office-of-the-spokesperson/2025/09/presidential-determination-on-major-drug-transit-or-major-illicit-drug-producing-countries-for-fiscal-year-2026](https://www.state.gov/releases/office-of-the-spokesperson/2025/09/presidential-determination-on-major-drug-transit-or-major-illicit-drug-producing-countries-for-fiscal-year-2026) - [https://www.hklaw.com/en/insights/publications/2026/03/fincen-imposes-record-penalty-on-broker-dealer](https://www.hklaw.com/en/insights/publications/2026/03/fincen-imposes-record-penalty-on-broker-dealer) - [Bollwerk AI](https://bollwerk.ai/blog/swiss-aml-revision-2026/) - [Bollwerk AI](https://bollwerk.ai/blog/finma-amlo-finma-consultation-2026/) - [https://www.admin.ch/de/newnsb/L0rkU9ZvCFSw](https://www.admin.ch/de/newnsb/L0rkU9ZvCFSw) - [https://www.admin.ch/de/newnsb/x3sKLxCJ6S3dQJtfvy0Tb](https://www.admin.ch/de/newnsb/x3sKLxCJ6S3dQJtfvy0Tb) - [https://www.bj.admin.ch/de/schweizerisches-transparenzregister](https://www.bj.admin.ch/de/schweizerisches-transparenzregister) - [https://www.sif.admin.ch/de/geldwaeschereigesetz-gwg](https://www.sif.admin.ch/de/geldwaeschereigesetz-gwg) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://www.sif.admin.ch/dam/de/sd-web/dUviLBIEgTjT/Faktenblatt%20Stablecoins.pdf](https://www.sif.admin.ch/dam/de/sd-web/dUviLBIEgTjT/Faktenblatt%20Stablecoins.pdf) - [https://caplaw.ch/2026/swiss-advisers-subject-to-the-swiss-anti-money-laundering-act-scope-and-duties/](https://caplaw.ch/2026/swiss-advisers-subject-to-the-swiss-anti-money-laundering-act-scope-and-duties/) - [https://www.mondaq.com/fintech/1851520/switzerlands-new-aml-regime-is-live-five-issues-for-fintechs-and-financial-platforms](https://www.mondaq.com/fintech/1851520/switzerlands-new-aml-regime-is-live-five-issues-for-fintechs-and-financial-platforms) - [https://mlroconsulting.com/aml-requirements/aml-requirements-switzerland/](https://mlroconsulting.com/aml-requirements/aml-requirements-switzerland/) - [https://cms.law/en/che/legal-updates/switzerland-revises-finma-anti-money-laundering-ordinance-main-changes](https://cms.law/en/che/legal-updates/switzerland-revises-finma-anti-money-laundering-ordinance-main-changes) - [https://www.sif.admin.ch/en/financial-action-task-force-2](https://www.sif.admin.ch/en/financial-action-task-force-2) - [https://en.wikipedia.org/wiki/MBaer_Merchant_Bank](https://en.wikipedia.org/wiki/MBaer_Merchant_Bank) - [https://goldblum.ch/crypto/crypto-licence-switzerland/](https://goldblum.ch/crypto/crypto-licence-switzerland/) - [https://www.legal500.com/guides/chapter/switzerland-gambling-law/?export-pdf=](https://www.legal500.com/guides/chapter/switzerland-gambling-law/?export-pdf=) - [Federal Department of Finance (EFD)](https://www.efd.admin.ch/en/newnsb/Amio6afANTmb) - [Swiss Federal Council](https://www.admin.ch/en/newnsb/x3sKLxCJ6S3dQJtfvy0Tb) - [Swiss Law firm newsletter (SWLegal)](https://www.swlegal.com/en/insights/newsletter-detail/partial-revision-of-the-amlo-finma/) - [Brussels Signal](https://brusselssignal.eu/2026/09/swiss-voters-reject-neutrality-initiative-keeping-sanctions-on-russia-in-place/) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Switzerland.html) - [https://www.grantthornton.ch/en/insights/new-aml-rules-asset-managers/](https://www.grantthornton.ch/en/insights/new-aml-rules-asset-managers/) - [https://didit.me/blog/sanctions-screening-switzerland-seco-eu-ofac-un/](https://didit.me/blog/sanctions-screening-switzerland-seco-eu-ofac-un/) - [https://didit.me/blog/seco-sanctions-list-switzerland/](https://didit.me/blog/seco-sanctions-list-switzerland/) - [https://www.amlintelligence.com/2026/09/breaking-switzerland-fines-julius-baer-e10-6m-chf10m-over-anti-money-laundering-failings/](https://www.amlintelligence.com/2026/09/breaking-switzerland-fines-julius-baer-e10-6m-chf10m-over-anti-money-laundering-failings/) - [https://news.easygov.swiss/news-en/transparency-register/](https://news.easygov.swiss/news-en/transparency-register/) - [Swiss Federal Administration](https://www.newsd.admin.ch/newsd/message/attachments/42658.pdf) - [Fedlex (Swiss Federal Chancellery)](https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1998/892_892_892/20230123/en/pdf-a/fedlex-data-admin-ch-eli-cc-1998-892_892_892-20230123-en-pdf-a.pdf) - [Didit](https://didit.me/blog/swiss-aml-kyc-requirements/) - [Didit](https://didit.me/blog/sanctions-screening-switzerland-seco-eu-ofac-un/) - [CMS Law](https://cms.law/en/che/legal-updates/switzerland-revises-finma-anti-money-laundering-ordinance-main-changes) - [Grant Thornton Switzerland](https://www.grantthornton.ch/en/insights/new-aml-rules-asset-managers/) - [BDO Switzerland](https://www.bdo.ch/de-ch/publikationen/finma-eroffnet-anhorung-zur-teilrevision-der-geldwaschereiverordnung-finma) - [Wikipedia](https://en.wikipedia.org/wiki/MBaer_Merchant_Bank) - [Goldblum](https://goldblum.ch/knowledgebase/travel-rule-switzerland/) - [SIGTAX](https://sigtax.com/Switzerland-AML-2026-New-Beneficial-Ownership-Rules) - [Bundesamt für Justiz / Gespa](https://www.gespa.ch/download/pictures/82/6xp3nx8cxv7641ixpg69ylvfic34n4/erlaueterungen-vo-d.pdf) - [Bundesamt für Justiz (BJ)](https://www.bj.admin.ch/dam/bj/de/data/wirtschaft/gesetzgebung/archiv/geldspielgesetz/vn-ber-vo.pdf.download.pdf/vn-ber-vo-d.pdf) - [odat.ch (consolidated Swiss federal law mirror)](https://ch.odat.ch/de/cc/955.0-20261001-de.html) - [regulatorik.ai](https://regulatorik.ai/en/framework/ch-gwg) - [Notabene](https://notabene.id/world/switzerland) - [Lexology](https://www.lexology.com/library/detail.aspx?g=1feeb3c1-c698-4434-9a78-7931679f9c90) - [Swiss Confederation (Fedlex)](https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/2015/390/20210101/de/pdf-a/fedlex-data-admin-ch-eli-cc-2015-390-20210101-de-pdf-a-3.pdf) - [Walder Wyss](https://www.walderwyss.com/assets/content/publications/1968.pdf) - [Loyens & Loeff](https://www.loyensloeff.com/insights/news--events/news/introduction-of-a-new-swiss-transparency-register/) - [Lenz & Staehelin](https://www.lenzstaehelin.com/news-and-insights/browse-thought-leadership-insights/insights-detail/introduction-of-a-federal-register-of-beneficial-owners/) - [money-laundering.ch](https://www.money-laundering.ch/gwg-obligations-in-the-event-of-suspected-money-laundering/reporting-duty) - [Bär & Karrer](https://www.baerkarrer.ch/en/publications/new-anti-money-laundering-duties-for-advisory-services-in-switzerland) - [Goldblum](https://goldblum.ch/knowledgebase/swiss-aml-obligations/) - [Bär & Karrer](https://www.baerkarrer.ch/userdata/files/publications/2018/Financial_crime_in_Switzerland_overview.pdf) - [Simmons & Simmons](https://www.swlegal.com/media/filer_public/a1/71/a171711a-ebe9-43d5-89d3-a68acffccc55/2023_sanctions_-_switzerland.pdf) - [Chambers and Partners](https://practiceguides.chambers.com/practice-guides/sanctions-2025/switzerland/trends-and-developments) - [SECO (State Secretariat for Economic Affairs)](https://www.lenzstaehelin.com/fileadmin/user_upload/_3__2026_06_30_SECO_FAQ_Interpretation_of_articles_of_UKRO_Status_as_of_30_June_2026_clean.pdf) - [Helvetica Register](https://helveticaregister.com/sanctions-compliance-swiss-companies-screening/) - [SanctionsLookup](https://sanctionslookup.com/switzerland-sanctions-screening-api) - [IntegrityNext](https://www.integritynext.com/resources/glossary/s/swiss-ordinance-on-due-diligence-and-transparency-vsotr) - [Wenger Vieli](https://www.wengervieli.ch/en-us/journal/article-and-podcast/due-diligence-and-reporting-obligations-on-non-financial-matters,-conflict-minerals-and-child-labour) - [Goldblum](https://goldblum.ch/financial-regulation/sro-membership/) - [money-laundering.ch](https://www.money-laundering.ch/gwg-due-diligence-obligation) - [MLRO Consulting](https://mlroconsulting.com/aml-requirements/aml-requirements-switzerland/) - [Nasdaq](https://www.nasdaq.com/solutions/fintech/nasdaq-compliance-hub/switzerland) - [Lexology](https://www.lexology.com/library/detail.aspx?g=6f3ea251-f666-49a6-b52d-da9033a34948) - [Charles Russell Speechlys](https://www.charlesrussellspeechlys.com/en/insights/expert-insights/dispute-resolution/2026/criminal-lawyers-switzerland-2026-corporate-criminal-liability-aml-risks--enforcement/) - [Global Law Experts](https://globallawexperts.com/switzerland-corporate-criminal-liability-2026/) - [FINMA](https://www.finma.ch/FinmaArchiv/bpv/download/e/FINMASA.pdf) - [FINMA](https://www.finma.ch/en/documentation/dossier/dossier-fintech/innovation-2021/) - [MME Legal](https://www.mme.ch/en/magazine/articles/finma-publishes-ico-guidelines) - [FINMA](https://www.finma.ch/en/documentation/dossier/dossier-fintech/innovation-und-aufsicht-2019/) - [PwC Switzerland](https://www.pwc.ch/en/insights/regulation/finma-stablecoin-guidance.html) - [FINMA (Swiss Financial Market Supervisory Authority)](https://www.finma.ch/FinmaArchiv/gwg/e/dokumentationen/gesetzgebung/bundesgesetzgebung/pdf/AMLA_e.pdf?lang=en) - [FluxForce](https://www.fluxforce.ai/jurisdictions/switzerland) - [https://www.finma.ch/en/news/2026/10/20261008-mm-video-und-onlineid](https://www.finma.ch/en/news/2026/10/20261008-mm-video-und-onlineid) - [https://www.finma.ch/en/documentation/dossier/dossier-geldwaeschereibekaempfung/hinweise-zur-revision-des-geldwaeschereigesetzes-und-der-geldwaeschereiverordnung/](https://www.finma.ch/en/documentation/dossier/dossier-geldwaeschereibekaempfung/hinweise-zur-revision-des-geldwaeschereigesetzes-und-der-geldwaeschereiverordnung/) - [https://www.admin.ch/de/newnsb/WFpbtbbMBSLL](https://www.admin.ch/de/newnsb/WFpbtbbMBSLL) - [https://www.finma.ch/en/news/2026/10/20261020-mm-finma-bitcoin-etf/](https://www.finma.ch/en/news/2026/10/20261020-mm-finma-bitcoin-etf/) - [https://www.finma.ch/de/news/2021/05/20210517-mm-rs-16-07-online-identifizierung/](https://www.finma.ch/de/news/2021/05/20210517-mm-rs-16-07-online-identifizierung/) - [Mutual Evaluation of Switzerland](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofswitzerland.html) - [Switzerland](https://www.fatf-gafi.org/en/countries/detail/Switzerland.html) - [First Biennial Update to the Swiss Mutual Evaluation Report](https://www.fatf-gafi.org/en/countries/s-t/switzerland/documents/firstbiennialupdatetotheswissmutualevaluationreport.html) - [Follow-up Report to the Mutual Evaluation of Switzerland](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Follow-upreporttothemutualevaluationofswitzerland.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [FATF](https://www.fatf-gafi.org/en/home.html) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Agreement on the Swiss banks' code of conduct with regard](https://www.unodc.org/documents/archive/imolin/chbcoc.pdf) - [Switzerland aims to track corporate ownership in attempt to curb money-laundering - ICIJ](https://www.icij.org/investigations/pandora-papers/switzerland-aims-to-track-corporate-ownership-in-attempt-to-curb-money-laundering/) - [Switzerland Proposes to Strengthen Anti-Money Laundering Laws | OCCRP](https://www.occrp.org/en/news/switzerland-proposes-to-strengthen-anti-money-laundering-laws) - [Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/St-Vincent-Grenadines-MER.pdf.coredownload.inline.pdf) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [Patchy Progress in Setting Up Public Beneficial Ownership Registers in the EU | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/anonymous-company-owners/5amld-patchy-progress/) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [BENEFICIAL OWNERSHIP OF LEGAL PERSONS MARCH 2023 MARCH 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf) - [Leaked Letters Give Insight Into Anti-Money Laundering Gaps at Swiss Bank Reyl | OCCRP](https://www.occrp.org/en/investigation/swiss-private-bank-reyl-investigated-for-money-laundering) - [Swiss Regulator to Get Power to Fine Banks Under Law Proposal - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-06/swiss-regulator-to-get-power-to-fine-banks-under-law-proposal) - [We Investigate Corruption. Swiss Law Calls That a Crime. | OCCRP](https://www.occrp.org/en/feature/we-investigate-corruption-swiss-law-calls-that-a-crime) - [Swiss Bank Sanctioned for Corruption | OCCRP](https://occrp.org/en/daily/11670-swiss-bank-sanctioned-for-corruption) - [Swiss Bank Execs Suspected in Money-Laundering Probe | OCCRP](https://www.occrp.org/en/news/swiss-bank-execs-suspected-in-money-laundering-probe) - [Crypto regulatory affairs: Swiss regulator publishes guidance for stablecoin issuers and banks offering guarantees](https://www.elliptic.co/blog/crypto-regulatory-affairs-swiss-regulator-publishes-guidance-for-stablecoin-issuers-banks-offering-guarantees) - [Prosecutors Decline To Investigate Claims OCCRP Violated Swiss Banking Secrecy Laws | OCCRP](https://www.occrp.org/en/news/prosecutors-decline-to-investigate-claims-occrp-violated-swiss-banking-secrecy-laws) - [MBaer Bank Under Swiss Investigation After US Money Laundering Claims - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-02/mbaer-bank-faces-preliminary-swiss-probe-over-iran-allegations) - [Swissquote Ordered by Regulator to Slash Suspicious Activity - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-01/swissquote-ordered-by-regulator-to-reduce-suspicious-activity) - [Memorandum of Understanding between OFAC and the Swiss State Secretariat for Economic Affairs | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250516) - [Switzerland’s Frozen Russian Assets Continue to Climb | OCCRP](https://www.occrp.org/en/news/switzerlands-frozen-russian-assets-continue-to-climb) - [Switzerland Has Frozen $14 Billion in Total of Russia Assets - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-23/switzerland-says-it-s-blocked-14-2-billion-of-russian-assets) - [Switzerland Froze 28% More Russian Assets in Past Year, Following EU - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-01/swiss-froze-28-more-russian-assets-in-past-year-following-eu) - [Switzerland Adopts Most of EU’s New Russia Sanctions Package - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-22/switzerland-adopts-most-of-eu-s-new-russia-sanctions-package) - [Switzerland Adopts Further EU Sanctions Targeting Russian Media - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-22/switzerland-adopts-further-eu-sanctions-targeting-russian-media) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Switzerland Adopts Additional EU Sanctions Against Russia - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-12/switzerland-adopts-additional-eu-sanctions-against-russia) - [ASSET FREEZE AND PROHIBITION TO MAKE FUNDS AND ECONOMIC RESOURCES AVAILABLE](https://finance.ec.europa.eu/document/download/c7265161-3d9c-42e2-a928-e5b38c02bb92_en?filename=faqs-sanctions-russia-assets-freezes_en.pdf) - [825 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/825) - [Guidance-Beneficial-Ownership-Transparency-Legal- ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf) - [FATF guidance TRANSPARENCY AND BENEFICIAL OWNERSHIP October 2014](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-transparency-beneficial-ownership.pdf.coredownload.pdf) - [BEST PRACTICES ON BENEFICIAL OWNERSHIP FOR LEGAL PERSONS OCTOBER 2019](https://www.fatf-gafi.org/content/dam/fatf/documents/Best-Practices-Beneficial-Ownership-Legal-Persons.pdf) - [New Open Source law in Switzerland | Interoperable Europe Portal](https://interoperable-europe.ec.europa.eu/collection/open-source-observatory-osor/news/new-open-source-law-switzerland) - [Register of People with Significant Control](https://assets.publishing.service.gov.uk/media/691c2c0c84a267da57d70645/register-of-people-with-significant-control.pdf) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Swiss Government Motions for Press Freedom in Country’s Finance Sector | OCCRP](https://www.occrp.org/en/news/swiss-government-motions-for-press-freedom-in-countrys-finance-sector) - [Authorities Raid Swiss Trader in Probe Linked to Russian Gold - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-16/authorities-raid-swiss-trader-in-probe-linked-to-russian-gold) - [Swiss Lawyers Hit by US Sanctions for Hiding Dirty Russian Money - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-30/swiss-lawyers-hit-by-us-sanctions-for-hiding-dirty-russian-money) - [19th package of sanctions against Russia: EU targets Russian energy, third-country banks and crypto providers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) - [Swiss Lawyer Imprisoned After Making Fraud Accusations | OCCRP](https://www.occrp.org/en/news/swiss-lawyer-imprisoned-after-making-fraud-accusations) - [Dubai Becomes New Switzerland for Traders of Russian Commodities - Bloomberg](https://www.bloomberg.com/news/articles/2022-06-21/dubai-becomes-new-switzerland-for-traders-of-russian-commodities) - [Frequently Asked Questions - Recently Updated | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/updated) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [Bankers Support Switzerland’s Decision not Change Banking Secrecy Law | OCCRP](https://www.occrp.org/en/news/bankers-support-switzerlands-decision-not-change-banking-secrecy-law) - [Switzerland to Tighten its Anti-Money Laundering Rules | OCCRP](https://www.occrp.org/en/news/switzerland-to-tighten-its-anti-money-laundering-rules) - [European Body Rebukes Switzerland Over Handling of Magnitsky Fraud Funds | OCCRP](https://www.occrp.org/en/news/european-body-rebukes-switzerland-over-handling-of-magnitsky-fraud-funds) - [Switzerland Slammed for Protecting Dubious Banks | OCCRP](https://occrp.org/en/daily/16007-switzerland-slammed-for-protecting-dubious-banks) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [North Korea IT Workers: Inside the DPRK’s Crypto Laundering Network](https://www.chainalysis.com/blog/dprk-it-workers-north-korea-crypto-laundering-networks/) - [OFAC lists 53 crypto addresses of sanctioned North Korean Cheil Credit Bank](https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank) - [2025 Crypto Theft Reaches $3.4 Billion](https://www.chainalysis.com/blog/crypto-hacking-stolen-funds-2026/) - [OFAC Targets DPRK IT Workers Using Crypto](https://www.chainalysis.com/blog/ofac-targets-north-korean-it-workers-crypto-march-2026/) - [Inside the FBI’s Virtual Assets Unit: Tackling Crypto Crime – Ep. 172](https://www.chainalysis.com/blog/inside-the-fbi-virtual-assets-unit-crypto-crime-ep-172/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Guidance on Transparency and Beneficial Ownership](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Transparency-and-beneficial-ownership.html) - [Switzerland Weighs New Money-Laundering Rules Amid US Criticism - Bloomberg](https://www.bloomberg.com/news/articles/2023-08-30/switzerland-weighs-tougher-anti-money-laundering-laws) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Transparency register - European Commission](https://ec.europa.eu/info/about-european-commission/service-standards-and-principles/transparency/transparency-register_en) - [Transparency register: Council agrees mandate for negotiations - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2017/12/06/transparency-register-council-agrees-mandate-for-negotiations/) - [Transparency register: Council adopts new rules making registration of interest representatives mandatory - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2021/05/06/transparency-register-council-adopts-new-rules-making-registration-of-interest-representatives-mandatory/) - [Finma Warns Immediate Mythos AI Access Poses Systemic Risk to Swiss Banks - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-24/finma-says-immediate-mythos-access-would-pose-systemic-bank-risk) - [Artificial intelligence risk brews for US banks as queries arise | Insights | Bloomberg Professional Services](https://www.bloomberg.com/professional/insights/financial-services/artificial-intelligence-risk-brews-for-us-banks-as-queries-arise/) - [Banks Urged to Embrace AI and Crypto Innovations by Fed's Top Watchdog - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-08-21/banks-urged-to-embrace-ai-and-crypto-innovations-by-fed-s-top-watchdog) - [OPPORTUNITIES AND CHALLENGES OF NEW TECHNOLOGIES FOR AML/CFT JULY 2021](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Opportunities-Challenges-of-New-Technologies-for-AML-CFT.pdf) - [AI Advances Raise Cybersecurity Concerns for US Banks, Treasury Secretary Warns - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-03/banks-in-us-are-working-to-gird-against-ai-attacks-bessent-says) - [Commission seeks input from industry on the use of artificial intelligence in finance | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/news/commission-seeks-input-industry-use-artificial-intelligence-finance) - [Statement by FinCEN Director Andrea M. Gacki before the House Committee on Financial Services, Subcommittee on National Security, Illicit Finance, and International Financial Institutions | FinCEN.gov](https://www.fincen.gov/news/testimony/statement-fincen-director-andrea-m-gacki-house-committee-financial-services) - [Targeted consultation on artificial intelligence in the financial ...](https://finance.ec.europa.eu/document/download/054d25f5-0065-488a-96fb-2bb628c74e6f_en?filename=2024-ai-financial-sector-consultation-document_en.pdf) - [Crypto regulatory affairs: CLARITY Act Senate delay creates uncertainty](https://www.elliptic.co/blog/crypto-regulatory-affairs-clarity-act-senate-delay-creates-uncertainty) - [Targeted consultation on artificial intelligence in the financial sector - Finance](https://finance.ec.europa.eu/regulation-and-supervision/consultations-0/targeted-consultation-artificial-intelligence-financial-sector_en) - [The Swiss privacy regulator establishes new compliance standards | Interoperable Europe Portal](https://interoperable-europe.ec.europa.eu/collection/open-source-observatory-osor/news/swiss-privacy-regulator-establishes-new-compliance-standards) - [UN Rapporteur: Swiss Banking Laws Curtail Free Speech | OCCRP](https://www.occrp.org/en/news/un-rapporteur-swiss-banking-laws-curtail-free-speech) - [Swiss Banking Secrecy Is Gone. Shell Companies Might Be Next](https://www.bloomberg.com/news/articles/2023-12-12/swiss-banking-secrecy-gone-now-reformers-are-targeting-legal-secrecy) - [Deal on Bank Secrecy | OCCRP](https://www.occrp.org/en/news/deal-on-bank-secrecy) - [Submission from the Government of Switzerland](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/switzerlands_comments.pdf) - [EU strengthens international tax cooperation with Switzerland - Taxation and Customs Union](https://taxation-customs.ec.europa.eu/news/eu-strengthens-international-tax-cooperation-switzerland-2025-10-20_en) - [Transparency - European Research Executive Agency - European Commission](https://rea.ec.europa.eu/transparency_en?prefLang=hr) - [Swiss Parliament | OCCRP](https://www.occrp.org/en/organizations/swiss-parliament) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Switzerland.html) - [US Department of the Treasury / OFAC](https://ofac.treasury.gov/recent-actions/20250516) - [European Commission](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [OCCRP](https://www.occrp.org/en/investigation/swiss-private-bank-reyl-investigated-for-money-laundering) - [OCCRP](https://www.occrp.org/en/news/european-body-rebukes-switzerland-over-handling-of-magnitsky-fraud-funds) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-09-16/authorities-raid-swiss-trader-in-probe-linked-to-russian-gold) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-06-06/swiss-regulator-to-get-power-to-fine-banks-under-law-proposal) - [Elliptic](https://www.elliptic.co/blog/crypto-regulatory-affairs-swiss-regulator-publishes-guidance-for-stablecoin-issuers-banks-offering-guarantees) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-04-02/mbaer-bank-faces-preliminary-swiss-probe-over-iran-allegations) Coverage gaps fim-int-2026-07-05-G001: Post-entry-into-force compliance an… fim-int-2026-07-05-G001: Post-entry-into-force compliance and enforcement effectiveness of the Swiss LETA beneficial-ownership register (effective 1 October 2026) has not yet occurred and requires monitoring once the register is operative. [resolved] fim-int-2026-07-05-G002: No specific FATF Recommendation-lev… fim-int-2026-07-05-G002: No specific FATF Recommendation-level citation (e.g., R.24, R.25) was supplied by the research bundle for Switzerland's technical-compliance ratings; a direct FATF technical-compliance annex reference would improve claim precision. [resolved] fim-int-2026-07-05-G003: The final disposition of FINMA's en… fim-int-2026-07-05-G003: The final disposition of FINMA's enforcement inquiry into Bank Reyl remains unconfirmed as of the baseline date; an updated FINMA enforcement determination or public statement would resolve the stale April 2025 status. [resolved] fim-int-2026-07-05-G004: Parliamentary passage timeline for … fim-int-2026-07-05-G004: Parliamentary passage timeline for the Banking Act revision granting FINMA direct fining powers is not yet confirmed; a scheduled parliamentary vote date would firm up the regulatory horizon uncertainty band. [resolved] fim-int-2026-07-05-G005: The underlying Switzerland baseline… fim-int-2026-07-05-G005: The underlying Switzerland baseline research bundle failed its automated publication gate (schema_valid=false, source-floor and T1-instrument thresholds unmet) and carries a hold_for_review challenge verdict; a remediated, gate-passing baseline would improve overall evidentiary confidence for this jurisdiction. [resolved] fim-int-2026-07-05-G006: The standing AMLA Work Programme, A… fim-int-2026-07-05-G006: The standing AMLA Work Programme, AMLR/6AMLD application-date, and AMLA direct-supervision horizon anchors were not populated this cycle because the Switzerland-focused research bundle did not supply CH-specific supporting evidence for these EU-wide instruments (which do not apply to non-EU Switzerland in any case). [resolved] fim-int-2026-07-07-G001: Full text of the LETA implementing … fim-int-2026-07-07-G001: Full text of the LETA implementing ordinance and the specific beneficial-ownership reporting thresholds/timelines by entity type has not been retrieved this cycle. [resolved] fim-int-2026-07-07-G002: Parliamentary passage timeline for … fim-int-2026-07-07-G002: Parliamentary passage timeline for the FINMA fining-power Banking Act revision (dispatch tabled 22 April 2026) is not established. [resolved] fim-int-2026-07-07-G003: Final status of the FinCEN Section … fim-int-2026-07-07-G003: Final status of the FinCEN Section 311 proposed rule against MBaer Merchant Bank (finalised, withdrawn, or amended) is not confirmed as of this cycle. [resolved] fim-int-2026-07-07-G004: Final outcome of FINMA's enforcemen… fim-int-2026-07-07-G004: Final outcome of FINMA's enforcement inquiry into Bank Reyl has not been publicly disclosed; current sourcing indicates status uncertainty beyond April 2026. [resolved] fim-int-2026-07-14-G001: The sanctions_changes[] schema's is… fim-int-2026-07-14-G001: The sanctions_changes[] schema's issuing_body enum (OFAC|OFSI|EU_Council|UN) has no value for Switzerland's own sanctions authority (SECO/EAER), preventing structured encoding of CH-specific sanctions changes this cycle; captured instead in domain_tracker D1 and structured_claims. [resolved] fim-int-2026-07-14-G002: No Tier-1 FINMA or Federal Council … fim-int-2026-07-14-G002: No Tier-1 FINMA or Federal Council consultation-page URL was retrieved for the FinIA reform; all corroboration is Tier-4 law-firm/vendor commentary, capping confidence at Assessed. [resolved] fim-int-2026-07-14-G003: D4 (Conflict Finance) and D6 (Compl… fim-int-2026-07-14-G003: D4 (Conflict Finance) and D6 (Compliance Technology) show no Switzerland-specific findings this cycle; absence not yet distinguished from under-search versus genuine null. [resolved] fim-int-2026-07-14-G004: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-07-14-G004: Tier D jurisdictions (KH, LA, MX, CO) were not searched this cycle as search budget was allocated to the CH-bound dispatch. [resolved] fim-int-2026-07-14-G005: No ratified typology library was su… fim-int-2026-07-14-G005: No ratified typology library was supplied in this dispatch context, so typology_observations[] could not be populated even though several developments (mirror/successor-entity sanctions evasion, sanctioned crypto-platform dealings) are plausible typology matches. [resolved] fim-int-2026-08-05-G001: No Tier-1 SECO/Fedlex primary sourc… fim-int-2026-08-05-G001: No Tier-1 SECO/Fedlex primary source retrieved for the 19th/20th EU sanctions package implementation this cycle; corroboration rests on two Tier-3 legal-sector summaries. [resolved] fim-int-2026-08-05-G002: No FINMA primary consultation-page … fim-int-2026-08-05-G002: No FINMA primary consultation-page URL retrieved for the AMLO revision; enforcement-intensity claims against named private banks lack a corroborating Tier-1/2 source. [resolved] fim-int-2026-08-05-G003: obligation_refs framework enum lack… fim-int-2026-08-05-G003: obligation_refs framework enum lacks a token for Swiss domestic instruments (Ukraine Ordinance Annex 13a; LETA/TJPG); citations are tracked in claim notes but cannot be classified into the closed framework enum this cycle. [resolved] fim-int-2026-08-05-G004: CH-specific conflict-finance (D4) e… fim-int-2026-08-05-G004: CH-specific conflict-finance (D4) exposure not directly evidenced this cycle; Tier D findings substituted for direct CH D4 coverage. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No fedlex.admin.ch or Federal Gazette primary text was retrieved this cycle for the TJPG/GwG reforms; all findings rest on T3 legal-commentary secondary sources. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): FINMA's own AMLO-FINMA consultation page was not directly retrieved this cycle; findings rest on two independent T3 law-firm commentaries. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (enabler jurisdictions), D4 (conflict finance) and Tier D watch jurisdictions (KH/LA/MX/CO) returned no CH-specific material this cycle. [resolved] fim-int-2026-10-04-G001: Tier-D jurisdiction collection (Cam… fim-int-2026-10-04-G001: Tier-D jurisdiction collection (Cambodia, Laos, Mexico, Colombia) was out of scope under this run's CH-only jurisdiction lock. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): UN Panel of Experts (Yemen) and OFAC/OFSI Houthi-linked channels were not actively queried this cycle; this is a coverage gap, not a confirmed no-change finding. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): The detailed GwG Art. 2 para 3bis threshold figures rest on secondary legal commentary (T3) rather than a directly retrieved Fedlex text this cycle. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No FedLex/official Federal Council commencement decree for the revised AMLA/LETA was retrieved directly this cycle; reliance is on two T3 commentary sources. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): FINMA's own AMLO-FINMA consultation page was not retrieved; reliance is on a single T3 law-firm commentary source. [resolved] fim-int-2026-10-11-G003: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-10-11-G003: Tier-D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle within the pooled union search budget. [resolved] fim-int-2026-10-18-G001: Tier D watch jurisdictions (Cambodi… fim-int-2026-10-18-G001: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not separately searched this cycle because this run is contractually bound to the single jurisdiction CH. [resolved] fim-int-2026-10-18-G002: FinIA stablecoin/crypto-institution… fim-int-2026-10-18-G002: FinIA stablecoin/crypto-institution reform dispatch to parliament remains unpublished; no fixed entry-into-force date or parliamentary timetable could be established this cycle. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): T1 primary SECO/FINMA ordinance text for the amended AMLA Art. 8 sanctions-organisation duty was not directly retrieved this cycle; confidence capped at Probable. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): Thin coverage this cycle on D3 enabler-jurisdiction depth beyond the Julius Baer action, and no new D4/D5/D6 material found. [resolved] fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Third-party reliance / outsourcing of CDD under Swiss AML law (delegation under Art 28 GwV-FINMA and liability allocation) was not located this research pass. [open] fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Research budget was exhausted before dedicated searches on compliance-technology supervisory expectations, nominee/bearer-share and foreign land-ownership disclosure, information-sharing/production-order deadlines, screening/monitoring calibration cycles, whistleblowing channels, and counter-proliferation-financing-specific duties. [open] fim-int-2026-11-01-G001: No CH-specific Russia-sanctions-eva… fim-int-2026-11-01-G001: No CH-specific Russia-sanctions-evasion, dark-fleet, tech-procurement or commodity-rerouting development was identified for D1 this cycle. [open] fim-int-2026-11-01-G002: No CH-specific enabler-jurisdiction… fim-int-2026-11-01-G002: No CH-specific enabler-jurisdiction (D3) development distinct from the already-captured GwG advisor-perimeter expansion was identified this cycle. [open] FIM-GAP-001 (D1): Following the Swiss Supreme Court's Decemb… FIM-GAP-001 (D1): Following the Swiss Supreme Court's December 2025 ruling that the confiscation method used against Magnitsky-case-linked funds was unlawful, prosecutors did not recalculate or refreeze the assets, allowing them to leave Switzerland; the Council of Europe Parliamentary Assembly passed a 43-7 resolution in April 2026 rebuking Switzerland's handling. FIM-GAP-002 (D2): Switzerland has no operative federal benef… FIM-GAP-002 (D2): Switzerland has no operative federal beneficial-ownership register in force; a draft bill has been pending since 2023 with no confirmed enactment date, leaving company and trust ownership opaque outside bank Form-A declarations. FIM-GAP-003 (D3): Banking Act Article 47 criminalises disclo… FIM-GAP-003 (D3): Banking Act Article 47 criminalises disclosure of client banking data, including to journalists exposing wrongdoing; a 2023 parliamentary vote declined to loosen the provision, and prosecutors continue to entertain complaints against journalists (dismissed in December 2025 in the Bank Reyl case). FIM-GAP-004 (D6): Prior to the June 2025 legislative proposa… FIM-GAP-004 (D6): Prior to the June 2025 legislative proposal, FINMA lacked the power to directly fine banks for regulatory breaches, a capability gap identified as a contributing factor in the agency's failure to pre-empt Credit Suisse's 2023 collapse. ## Evidence #### Confidence-tiered claims Swiss Transparency Register began live operation 1 October 2026, administered by the Federal Office of Justice [[Source 1]](#sec-sources) Probable · 1 source Revised Anti-Money Laundering Act (GwG, SR 955.0) entered into force 1 October 2026 alongside the TJPG [[Source 1]](#sec-sources) Probable · 1 source Lawyers, notaries, fiduciaries and M&A/company-formation advisers brought into AML perimeter on an activity basis (five trigger categories), subject to professional-activity thresholds and 6-month SRO affiliation deadline [[Source 1]](#sec-sources) Probable · 1 source FATF 5th-round mutual evaluation: on-site period possibly June 2027, plenary discussion possibly February 2028 [[Source 1]](#sec-sources) Probable · 1 source AMLR/6AMLD/AMLA (EU AML Package) does not apply to CH as it is EFTA but not EEA [[Source 1]](#sec-sources) Probable · 1 source FinIA amendment proposing Payment Instrument Institution and Crypto-Institution licence categories; consultation closed 6 Feb 2026, entry into force not before 2027 [[Source 1]](#sec-sources) Probable · 1 source Federal Council implemented EU's 20th sanctions package on 19-20 August 2026; no new CH-specific designation dated in-window [[Source 1]](#sec-sources) Probable · 1 source Revised Anti-Money Laundering Act and new Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners entered into force 1 October 2026, creating a federal beneficial-ownership register (25% ownership/control threshold) and a new discrepancy-reporting duty for financial intermediaries, with staggered entity-registration deadlines running 31 December 2026 to 31 March 2027. [[Source 1]](#sec-sources) Probable · 1 source FINMA launched a consultation on 12 May 2026 on a partial revision of its Anti-Money Laundering Ordinance, amending Articles 1 and 8 of the AMLA to require organisational measures against breaches of coercive measures under the Embargo Act, implementing FATF Recommendations 1 and 2 on proliferation financing, with entry into force expected late 2026. [[Source 1]](#sec-sources) Probable · 1 source Switzerland's 5th-round mutual evaluation has a possible onsite period of June 2027 and a possible Plenary discussion in February 2028; no plenary action this cycle. [[Source 1]](#sec-sources) Probable · 1 source FINMA revoked MBaer's banking licence and ordered liquidation after finding the bank had assisted clients in circumventing official asset freezes; the bank withdrew its appeal on 27 February 2026, allowing the order to take effect. [[Source 1]](#sec-sources) Uncertain · 1 source FinIA-reform consultation (payment-instrument and crypto-institution licence categories) closed 6 February 2026; entry into force not expected before 2027, with some commentary citing 2028. [[Source 1]](#sec-sources) Probable · 1 source stable overall ML/TF risk exposure; leading threats are organised crime, corruption, and property/tax crime, each with an international dimension [[Source 1]](#sec-sources) Probable · 1 source Revised Anti-Money Laundering Act and new Transparency of Legal Entities and Identification of Beneficial Owners Act (TJPG) entered into force 1 October 2026, establishing a non-public federal beneficial-ownership register (>25% ownership/control threshold) and extending AML duties to lawyers, notaries and other advisors performing defined high-risk activities [[Source 1]](#sec-sources) Probable · 1 source AMLO-FINMA partial revision (sanctions-circumvention screening, ownership/control-structure traceability, correspondent-banking controls amending Art. 9b and Art. 37(5)) consultation closed 9 June 2026, expected in force 1 January 2027 [[Source 1]](#sec-sources) Probable · 1 source Swiss voters rejected a proposal to enshrine a stricter definition of neutrality in the constitution, preserving the Federal Council's discretion to align with EU/UN sanctions, including those on Russia [[Source 1]](#sec-sources) Probable · 1 source Compliant on 8 Recommendations, largely compliant on 29, partially compliant on 3 [[Source 1]](#sec-sources) Probable · 1 source The Swiss Transparency Register began operations on 1 October 2026 under the Transparency Act, requiring every legal entity subject to the reporting requirement to register once and report changes to beneficial owners. [[Source 1]](#sec-sources) Probable · 1 source Since 1 October 2026, Article 8 of the AMLA explicitly requires financial intermediaries to take organisational measures to prevent breaches of coercive measures under the Embargo Act. [[Source 1]](#sec-sources) Probable · 1 source FINMA concluded enforcement proceedings against Julius Baer over private loans to a European group and business ties with two Russian PEPs; ordered a CHF 250 million capital add-on and regular compliance reporting; the fine totalled CHF 10m. [[Source 1]](#sec-sources) Probable · 1 source Switzerland will undergo its fifth-round FATF mutual evaluation, with possible onsite assessment period 2027-06-01 and possible plenary discussion 2028-02-01. [[Source 1]](#sec-sources) Probable · 1 source Switzerland delayed automatic cross-border crypto tax data-sharing (OECD CARF) to at least 2027 while embedding CARF into domestic law from 1 January 2026. [[Source 1]](#sec-sources) Probable · 1 source Art. 8 AMLA, in force since 1 October 2026, requires organisational measures to prevent violations of Embargo Act coercive measures [[Source 1]](#sec-sources) Probable · 1 source New Art. 30 AMLO-FINMA, expected in force 1 January 2027, requires measures to prevent Embargo Act violations, cross-referenced with AML provisions [[Source 1]](#sec-sources) Probable · 1 source New Art. 37 para. 5 restricts correspondent-banking pass-through (Durchlaufkonten) payments for contracting-party customers absent customer-information disclosure on request [[Source 1]](#sec-sources) Uncertain · 1 source FINMA revoked MBaer Merchant Bank AG's banking licence and ordered liquidation in early 2026 for systemic AML due-diligence deficiencies, including assisting clients in circumventing asset freezes [[Source 1]](#sec-sources) Uncertain · 1 source CHF 1,000 identification threshold applies to virtual-asset transfers, with no exemption for self-hosted wallets [[Source 1]](#sec-sources) Probable · 1 source Full identification required at CHF 15,000 (player-account deposits) and CHF 25,000 (winnings transfer) for large-game organisers; CHF 25,000/15,000/10,000/5,000 thresholds apply to non-online casino games [[Source 1]](#sec-sources) Probable · 1 source Dealers must apply CDD once cash receipts in a trading transaction exceed CHF 100,000, with tranches aggregated to prevent structuring [[Source 1]](#sec-sources) Probable · 1 source CHF 15,000 from 1 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Registration within one month of Commercial Register entry, effective 1 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Effective 1 October 2026; SRO application deadline 1 December 2026 for already-active advisers [[Source 1]](#sec-sources) Probable · 1 source On knowledge or reasonable suspicion of money laundering/terrorist financing [[Source 1]](#sec-sources) Probable · 1 source Without delay, including for >50%-Russian-owned non-EEA enterprises [[Source 1]](#sec-sources) Probable · 1 source Partial revision enters into force 1 November 2026, admitting the Swiss e-ID for online identification, treating QR-code IDs as MRZ-equivalent, and adding a liveness-detection requirement linked to AI impersonation risk. [[Source 1]](#sec-sources) Probable · 1 source Both entered into force 1 October 2026, extending GwG due-diligence duties to a defined set of advisors and creating a non-public federal beneficial-ownership register run by the Federal Office of Justice. [[Source 1]](#sec-sources) Probable · 1 source Approved Switzerland's first retail Bitcoin ETF on 20 October 2026, applying its January 2026 crypto-custody guidance as the operational template and granting an exemption from standard fund risk-diversification rules. [[Source 1]](#sec-sources) Probable · 1 source