Switzerland's partial revision of the Anti-Money Laundering Act (Geldwäschereigesetz, GwG, SR 955.0), brought into force by the Federal Council for October 1, 2026, extends the Act's personal scope to advisors (Beraterinnen und Berater) under Article 2 paragraphs 3bis to 3quater GwG. Nine due-diligence obligations fall due on that date on the lawyers, notaries, fiduciaries and real-estate and company-formation advisors who become financial intermediaries.
Swiss lawyers, notaries, fiduciaries and real-estate and company-formation advisors, and domicile or seat-address providers active for more than six months, must affiliate to a FINMA-recognised self-regulatory organisation (SRO), run customer due diligence and beneficial-owner identification under Articles 3 to 7 GwG, report suspicious activity to MROS under Article 9 GwG, keep records for 10 years, build a risk-based internal AML organisation and consult the federal Transparency Register by October 1, 2026, or lose the legal capacity to perform covered activities and face FINMA enforcement measures and criminal liability under the GwG and the Swiss Criminal Code.
- Deadline : October 1, 2026, entry into force of the revised GwG (SR 955.0); nine advisor obligations apply from that date
- Who : Swiss lawyers, notaries, fiduciaries, real-estate and company-formation advisors, and domicile or seat-address providers active for more than six months
- What : SRO affiliation, customer due diligence and beneficial-owner identification (Art. 3-7 GwG), MROS suspicious-activity reporting (Art. 9 GwG), 10-year record-keeping, risk-based internal AML organisation, Transparency Register consultation
- Otherwise : no SRO affiliation blocks covered activity; FINMA enforcement measures and criminal liability under the GwG and the Swiss Criminal Code
- Official source : GwG amendment, BBl 2025 2899 (fedlex)
What is due on October 1, 2026
Nine obligations fall due when the revised GwG enters into force: SRO affiliation; customer due diligence and beneficial-owner identification (Articles 3 to 7 GwG); suspicious-activity reporting to MROS (Article 9 GwG, with advisors added as reporting parties under the revised MGwV); 10-year record-keeping; a risk-based internal AML organisation; and Transparency Register consultation with a duty to report beneficial-owner discrepancies. The Federal Assembly adopted the revision on September 26, 2025, the optional referendum period expired unused on January 15, 2026, and the Federal Council set entry into force for October 1, 2026.
Who is covered
The revision captures as financial intermediaries anyone who, on a professional basis, assists third parties with financial transactions relating to the purchase and sale of real estate; the creation, management, administration, contributions and distributions of non-operating legal entities; and the purchase and sale of legal entities effected through a non-operating entity. It also covers domicile or seat-address providers active for more than six months and public-law notaries (Urkundspersonen). In practice this brings in lawyers, notaries, fiduciaries (Treuhänder), real-estate and company-formation advisors operating in the Swiss market.
Carved out: lawyers and notaries in litigation, arbitration, administrative or criminal proceedings and purely procedural advice (Article 2 paragraph 4 letter f); audit firms supervised by the Federal Audit Oversight Authority (RAOB/RAB) for audit activity (Article 2 paragraph 4bis); and low-risk transfers, including family, marital, inheritance, gift and intra-group transfers and real-estate or share-deal transfers below the CHF 5 million ordinance threshold (Article 2 paragraph 4ter).
What to do before October 1, 2026
- Affiliate to a FINMA-recognised SRO; advisors already active on the in-force date must submit the SRO application without delay.
- Set up customer due diligence: client identification, beneficial-owner identification, purpose and ongoing monitoring (Articles 3 to 7 GwG).
- Establish internal reporting channels to MROS for suspicious activity under Article 9 GwG.
- Implement 10-year record-keeping for CDD documentation and transaction records.
- Build a risk-based internal AML organisation: risk analysis, written policies, staff training and internal controls.
- Integrate federal Transparency Register consultation into client onboarding and report beneficial-owner discrepancies.
- Confirm scope per activity: map which engagements are covered (Article 2 paragraphs 3bis to 3quater) and which fall under the litigation, audit or low-value carve-outs.
What happens otherwise
Without SRO affiliation, an advisor cannot legally perform covered activities: affiliation is the gateway to operating as a GwG financial intermediary. FINMA may open enforcement measures, including banning and confiscation orders, against advisors that breach their due-diligence, reporting or record-keeping duties; failures of customer due diligence, MROS reporting and record-keeping also carry criminal liability under the GwG and the Swiss Criminal Code. FINMA supervises SRO compliance, MROS at fedpol receives the reports, and the Federal Office of Justice operates the Transparency Register. Continuous per-jurisdiction monitoring surfaces guidance and enforcement signals as they publish.
