The Swiss Financial Market Supervisory Authority (FINMA) has published the final partial revision of its Anti-Money Laundering Ordinance following the consultation launched in May 2026. The changes reflect amendments to the Anti-Money Laundering Act (AMLA) and the Federal Council’s ordinance ahead of the forthcoming Financial Action Task Force mutual evaluation.
Following consultation, FINMA clarified that Article 37 paragraph 5 applies only to clients of foreign respondent banks with direct access to the correspondent bank’s accounts. For these clients, the respondent bank must provide information needed for due diligence on request. The explanatory notes clarify the approach to ownership and control transparency according to risk, documentation requirements and the relationship with rules on complex structures and domiciliary companies. They also explain how requirements for monitoring business relationships and transactions apply by analogy to measures preventing breaches of sanctions under the Embargo Act.
FINMA also recognised the revised Swiss banks’ due diligence code and the revised regulations of the Self-Regulatory Organisation of the Swiss Insurance as minimum standards. The ordinance and both sets of standards take effect on January 1, 2027, with each set of standards providing a four-month transition period. Separate guidance on Circular 2011/1 clarifies its scope and supervisory responsibilities for advisory activities, following the AMLA’s extension to certain advisory services.