Switzerland’s New AML & Transparency Reforms – What You Need to Know

Switzerland is introducing major enhancements to its anti-money-laundering (AML) and corporate-transparency regime, and it matters not just for banks, but for companies and professionals across the board, including lawyers, notaries and advisors.

At the centre of the changes are two pieces of legislation adopted by the Swiss Parliament on 26 September 2025: the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) (also called “TLEA” or “TJPG”) and a revision of the Anti Money Laundering Act (AMLA). Le Cocq Associates+3LALIVE+3Bär & Karrer+3

Key changes in plain terms

1. Central transparency register for beneficial owners , Most Swiss companies (for example corporations, limited-liability companies, cooperatives) – and also certain foreign entities that have a Swiss branch or own Swiss real estate – must identify their “beneficial owners” (any natural persons who alone or with others control 25 % or more of capital or votes, or control by other means). They must submit this information to a new federal register. Bär & Karrer+2Lexology+2
2. Obligations extended to advisory professionals (lawyers, notaries, advisors) , The revised AMLA now explicitly brings into scope professionals who assist with certain higher-risk transactions: for example setting up, managing, or financing non-operational legal entities; purchasing or selling real estate; managing or administering legal entities. These professionals will now have to apply due diligence: identify clients and beneficial owners, document transaction purposes, keep records, and affiliate with a recognized self-regulatory body (SRO). Bär & Karrer+2Le Cocq Associates+2
3. Stricter rules apply to legal entities and increase in sanctions , The new transparency law sets fines of up to CHF 500,000 for intentional breaches of the notification or cooperation obligations. LALIVE

What this means for companies in Switzerland

• Any Swiss company within scope needs to review its ownership structure: identify beneficial owners, gather required data (name, date of birth, nationality, address, nature and extent of control) and be ready to submit this to the transparency register. Bär & Karrer+1
• Companies must keep that data updated and notify changes within one month of discovering them. Bär & Karrer
• For lawyers, notaries and advisors offering structuring, real-estate, corporate-entity or trust services, the old assumption that they operate outside AML obligations is no longer valid: they need to build or enhance AML programs, client-due-diligence policies, record-keeping and identify beneficial owners.
• Firms should reassess their relationships with clients who use Swiss entities or trusts, ensure transparency of the chain of ownership and evaluate whether they fall into the expanded “advisor” category under the AMLA.
• FInternal governance, training, monitoring and possible external affiliation (SRO) obligations will become relevant.

Why now?

The reforms respond to international pressure. The global standard-setting body Financial Action Task Force (FATF) has identified gaps in Switzerland’s AML/CTF (counter-terrorist-financing) framework, especially around beneficial-ownership transparency and enablers (advisors who help structure entities). Moody's+1 The reforms will bring Switzerland more fully into line with international norms, help preserve its reputation as a business-location and financial-center, and strengthen regulatory cooperation. Swiss Federal News

Steps to prepare

• Conduct a gap-analysis: identify whether your entity or the firms you advise are within scope of the new rules.
• Map and verify beneficial-ownership data; prepare the process for submission to the register.
• For advisors/law firms/corporate-service providers: review client-onboarding, due-diligence and record-keeping procedures; ensure you have risk-based AML procedures.
• Update internal policies, training and oversight (governance) to cover the expanded obligations.
• Monitor the forthcoming implementing ordinances from the Swiss Federal Council (which will spell out details) and note that entry-into-force is planned for mid-2026. Bär & Karrer+1

In summary

Switzerland is shifting its transparency and AML regime in a meaningful way , the old model of limited obligations for non-financial professionals and non-public ownership regimes is being replaced with a register of beneficial owners and an extension of AML duties into advisory professions. This matters for every company playing in Switzerland and every lawyer/notary/advisor offering entity-formation or real-estate services. Being proactive now will ease adaptation, reduce risk and maintain trust in Switzerland’s business environment.