Switzerland has opened a consultation on a new anti-money laundering package that would widen the scope of compliance obligations beyond traditional financial intermediaries and into selected advisory activities. The reform is designed to improve transparency around legal entities, strengthen due diligence in higher-risk services, and align the country more closely with international AML standards.
What the consultation covers
The Federal Council launched the consultation procedure in Bern on 30 August 2023 for a bill intended to strengthen Switzerland’s anti-money laundering framework. The proposal includes a federal register of beneficial owners, new due diligence rules for particularly risky consultancy activities, and additional measures aimed at preventing money laundering, terrorist financing, and sanctions evasion. According to the government, the overall objective is to protect the integrity and competitiveness of Switzerland as both a financial centre and a business location.
A key feature of the package is the creation of a non-public federal register in which companies and other legal entities would have to be entered together with information on their beneficial owners. The register is intended to help prosecutors identify who is really behind a legal structure more quickly and with greater certainty. The Federal Department of Justice and Police would manage the system, while an audit unit within the Federal Department of Finance would check data quality and, where necessary, issue penalties.
Expanded AML scope
The consultation also proposes extending anti-money laundering due diligence to certain consultancy activities, especially legal advice, where the risk of money laundering is considered elevated. The government specifically pointed to the structuring of companies and transactions involving real estate as particularly risky areas. At the same time, it said the position of the legal profession and the duty of professional secrecy for lawyers and notaries would be respected.
In its current AML framework update, Switzerland says the partial revision of the Anti-Money Laundering Act now covers certain consultancy services related to real estate transactions and the establishment or structure of legal entities. The State Secretariat for International Finance also notes that the revised AMLA extends the scope of the act and that the related legal changes are expected to enter into force in the second half of 2026. This indicates that the consultation process has already fed into a broader legislative package that is moving toward implementation.
Additional measures
Beyond beneficial ownership transparency and advisory-sector due diligence, the reform includes measures to prevent breaches or circumvention of sanctions under embargo legislation. It also lowers the cash-payment threshold in precious metals trading from CHF 100,000 to CHF 15,000. Cash payments above that level would still be allowed, but they would be subject to due diligence rules.
The package further tightens the rules for real estate transactions by subjecting all cash payments in real estate business to AML due diligence, regardless of amount. These changes are intended to reduce the misuse of cash-intensive sectors and close gaps that can be exploited for illicit financial flows. Swiss authorities present the reform as a response to the risks posed by criminal abuse of legal entities, organized crime, tax evasion, and sanctions circumvention.
Policy context
The reform is part of a longer Swiss effort to update AML safeguards in line with the Financial Action Task Force’s standards. The government said the measures are aligned with international expectations and are meant to strengthen Switzerland’s defence against financial crime. In the official AML overview, the State Secretariat for International Finance says illegal financial flows undermine financial-sector integrity and fuel crime, terrorism, and corruption at home and abroad.
Switzerland has already moved further in this direction: Parliament passed the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, along with the revised AMLA, on 26 September 2025. That law creates a centralised federal transparency register and expands AMLA coverage to certain consultancy services linked to real estate and legal-entity structuring. The legislation is expected to come into force in the second half of 2026.
Timeline and process
Under the 2023 consultation, the public comment period was scheduled to run until 29 November 2023, after which the Federal Council planned to submit its dispatch to Parliament in 2024. The later 2025 legislation shows that the policy direction set in the consultation has since advanced through the legislative process. For businesses and advisers, the practical implication is that compliance obligations are moving toward a more transparent and risk-based framework.
The government also said the reform would impose only a limited burden on smaller companies, with a simplified reporting procedure for most entities such as sole proprietorships, limited liability companies, associations, and foundations. It estimated the initial administrative burden at roughly 20 minutes of work on average in the first year, with less effort in later years. That assessment suggests the authorities are trying to balance stronger oversight with proportionate implementation.
Market impact
For financial intermediaries, lawyers, notaries, corporate service providers, and real estate professionals, the changes signal a broader compliance perimeter. Firms operating in higher-risk areas may need enhanced client onboarding, beneficial ownership checks, record-keeping, and suspicious activity reporting procedures. The proposed and later adopted measures also increase pressure on service providers to understand when advisory work triggers AML duties.
The reforms are likely to matter well beyond Switzerland because the country remains a major international financial centre. By moving toward a public-sector beneficial ownership register and wider AML coverage for advisory services, Switzerland is signalling stronger transparency expectations ahead of future international review cycles. In practical terms, the consultation and the subsequent legislation mark a shift from a narrower intermediary-based model to a broader, risk-based compliance regime.