The Swiss Financial Market Supervisory Authority has opened a consultation on a partial revision of its Anti-Money Laundering Ordinance for financial intermediaries. The draft would align the ordinance with amendments to the Anti-Money Laundering Act, implement remaining Financial Action Task Force recommendations and codify parts of FINMA’s supervisory practice. In practical terms, firms would need to be able to understand a customer’s ownership and control structure, take more clearly specified measures to prevent breaches of coercive measures under the Embargo Act, and meet stricter conditions when processing payments through certain correspondent banking arrangements. The proposal would require payments via transitory or payable-through accounts to be executed only where the customer can provide the client information needed for due diligence on request. It would also require a declaration on the beneficial owner where a contracting party maintains sub-accounts for individual clients. In addition, FINMA would repeal the provision that treated payments to and from Liechtenstein as domestic payments without a full data set, and update references to recognized self-regulation for banks, securities firms and insurers. The consultation runs until 9 June 2026. FINMA’s Board of Directors will review the responses and publish an outcome report, and the revised ordinance is intended to enter into force on 1 January 2027 alongside revised banking and insurance self-regulatory rules.