Switzerland Launches Landmark Consultation to Overhaul AML Framework and Introduce Central Beneficial Ownership Register

The Swiss Federal Council has initiated a sweeping transformation of the country’s anti-money-laundering (AML) framework, launching a public consultation on new ordinances that will define the mechanics of Switzerland’s long-anticipated transparency regime for legal entities. Running through January 2026, the consultation lays the foundation for the creation of a centralized beneficial ownership register and a significant expansion of the Anti-Money Laundering Act (AMLA) to encompass consultancy activities historically exploited for illicit financial flows. This development marks Switzerland’s most ambitious AML reform in over a decade and signals mounting international pressure on the nation to curb corporate secrecy and align with global transparency standards.

At the heart of the reform is the Transparency of Legal Entities and Identification of Beneficial Owners Act, a legislative milestone that represents a decisive departure from Switzerland’s long-standing culture of discretion surrounding company ownership. The act mandates a central register identifying and verifying the individuals who ultimately control legal entities, effectively closing loopholes that have allowed hidden ownership structures to persist. The Federal Department of Justice and Police will manage the register, while an independent audit unit under the Federal Department of Finance will oversee the verification of submitted data to ensure its accuracy and reliability.

Under the new rules, all companies will be required to disclose detailed information about their ownership and control hierarchies, including intermediary entities, ensuring the traceability of ultimate beneficial owners. The obligations will extend beyond traditional corporations to include foundations, trusts with Swiss connections, and partnerships — areas long vulnerable to opacity and misuse. The initiative directly responds to deficiencies identified by international bodies in Switzerland’s approach to beneficial ownership transparency and aims to bring the country into closer alignment with Financial Action Task Force (FATF) standards.

The reform also enhances access to verified ownership information for institutions subject to the AMLA, including banks, fiduciaries, and external asset managers. These entities will gain streamlined, real-time access to the central register, improving their ability to detect and monitor complex money movements through the Swiss financial and corporate ecosystem. By prioritizing data integrity and timely updates, Swiss authorities intend to ensure that beneficial ownership information remains accurate and actionable, rather than static or outdated.

Equally transformative is the planned expansion of the AMLA’s scope to include consultancy services tied to the establishment, structuring, and financing of legal entities — sectors long identified as conduits for money laundering. The revised framework brings corporate service providers, financial advisers, and intermediaries under the same compliance obligations as banks, effectively closing one of the most persistent blind spots in the country’s financial crime controls. These consultants will now be required to conduct full customer due diligence, verify client and beneficial owner identities, and report any suspicious activities to competent authorities.

This expansion recognizes that professional enablers — often positioned as neutral facilitators — have played a critical role in concealing ownership chains and legitimizing illicit capital flows. The revised AMLA not only aligns Switzerland’s oversight structure with FATF recommendations but also sends a strong signal that advisory and consultancy professions will no longer remain beyond the reach of AML scrutiny.

The updated Anti-Money Laundering Ordinance outlines the precise range of covered consultancy activities and delineates supervisory responsibilities. Firms engaged in asset structuring, corporate domiciliation, or similar advisory work will now be subject to the same monitoring standards as financial institutions. In addition, the ordinances aim to strengthen cooperation between supervisory authorities, financial intelligence units, and law enforcement through unified reporting protocols and shared data systems, addressing long-standing fragmentation within Switzerland’s oversight architecture.

A key innovation in the proposed framework is the creation of a data verification system administered by the Federal Department of Finance. This mechanism will ensure that beneficial ownership information is not only submitted but also regularly reviewed and updated. Non-compliance — whether through failure to report, delayed updates, or submission of inaccurate data — will carry significant penalties, including administrative fines and potential restrictions on business operations.

The dual-agency oversight model introduced under the reform seeks to balance strict enforcement with proportionality. The Federal Department of Justice and Police will be responsible for maintaining and granting access to the beneficial ownership register, while the Federal Department of Finance will oversee audit and data integrity functions. This division of responsibilities is designed to enhance accountability and prevent regulatory capture.

Another crucial component of the proposal is the modernization of inter-agency communication. The ordinances establish channels for real-time exchange of beneficial ownership data between supervisory bodies, the financial intelligence unit, and prosecutorial authorities. This interoperability is intended to eliminate redundant requests, accelerate information flow, and enable early identification of inconsistencies across datasets — a vital capability for uncovering complex layering schemes that rely on shell entities.

Swiss authorities have emphasized that these reforms are aligned with FATF’s upcoming mutual evaluation cycle. By embedding transparency, data accuracy, and proactive oversight into its AML strategy, Switzerland aims to reinforce its global reputation, counter long-standing criticisms of its financial secrecy culture, and demonstrate tangible progress toward international compliance. The implementation timeline will be closely synchronized with FATF’s review schedule to underscore Switzerland’s commitment to reform.

The transition to a transparency-based model will, however, pose significant challenges for several industries. Corporate service providers, fiduciaries, and family offices will need to adapt to new verification, recordkeeping, and reporting requirements. Entities accustomed to discretion will face operational and cultural shifts, including the overhaul of client communication practices and the introduction of robust data management systems.

A major implementation hurdle lies in reconciling beneficial ownership data across Switzerland’s decentralized registry landscape. With cantonal systems operating under varying standards, achieving uniformity between federal and regional data repositories will be a complex undertaking. The planned central register is expected to streamline this process by replacing fragmented databases with a single, standardized federal platform.

Legal analysts anticipate a phased rollout of the framework, with initial emphasis on high-risk sectors such as real estate, fiduciary management, and corporate formation services. The ordinance-based model offers the flexibility to refine definitions and enforcement mechanisms over time, allowing for iterative adaptation as the system matures. Early participation from regulated entities will be essential to avoid bottlenecks and ensure a smooth transition once the ordinances take effect.

From an enforcement perspective, the reforms represent a decisive pivot from reactive investigation to preventive transparency. By granting financial institutions and regulators access to verified ownership data, authorities aim to identify beneficial owners more quickly, assess risk more accurately, and freeze suspect assets before they can be transferred offshore. This capability is expected to significantly enhance the detection and disruption of cross-border laundering and terrorist financing operations.

Expanding AML coverage to consultants marks an acknowledgment that money laundering networks extend far beyond the banking system. Integrating these actors into the AML framework will strengthen collaboration among compliance professionals, tax authorities, and law enforcement agencies — a critical step in preventing the misuse of Swiss corporate structures to conceal proceeds of crime, facilitate tax evasion, or shield politically exposed persons’ wealth.

Through this consultation, Switzerland is taking a major step toward aligning its financial transparency regime with international expectations. The proposed ordinances, if adopted, will not only redefine corporate accountability but also signal a new era in which Swiss AML policy is grounded in verified data, proactive supervision, and a commitment to transparency without compromising regulatory precision.

By fLEXI tEAM