Swiss AML Act Revision 2026: New Duties for Advisers From 1 October

Switzerland has long regulated banks and other financial intermediaries under its Anti-Money Laundering Act (AMLA), but advisers such as lawyers, accountants and consultants have mostly sat outside it. That changes with the revision of the Act that takes effect on 1 October 2026. This guide summarises the changes affecting advisory services, based on a Bär and Karrer legal insight published on 16 June 2026. It is a secondary source, and whether a particular adviser is covered requires a case-by-case analysis, so read the revised Act and take advice before you rely on this summary.

Key dates

According to Bär and Karrer, the revised AMLA takes effect on 1 October 2026, together with the new Federal Act on the Transparency of Legal Entities. Advisers who are already carrying out covered activities on that date must submit an application to a self-regulatory organisation (SRO) by 1 December 2026. The source does not say what happens to advisers who start covered activities later, so check that point directly.

Who is affected

The new rules apply to advisers acting in or from Switzerland whose professional advice causally contributes to covered transactions linked to financial transactions. The source names lawyers, notaries, real estate brokers, consultants, accountants and other advisers. It does not mention fiduciaries specifically, so their position is unclear from this source.

Advice counts as professional if it is independent, economically sustained and aimed at permanent income. The source says it is always treated as professional if any of the following applies in a calendar year.

• Gross advisory revenue exceeds CHF 50,000.
• More than 20 clients or relevant transactions are handled.
• The advice concerns assets over CHF 5 million.
• The related financial transactions exceed CHF 2 million.

Which activities are covered

The rules focus on non-operating entities and real estate. The activities listed are:

• buying and selling real estate, which is covered once both parties have declared their intention to conclude the sale, unless an exemption applies;
• incorporating non-operating entities, whether seated in Switzerland or abroad;
• managing and administering non-operating entities;
• capital contributions to and distributions from non-operating entities; and
• buying and selling legal entities where the deal runs through a non-operating entity.

The source does not list the exemptions for real estate transactions, so check the Act itself.

New duties for covered advisers

1. Join an SRO. Advisers must become members of a self-regulatory organisation supervised by the Swiss financial regulator, FINMA.
2. Build an AML framework. This includes an onboarding concept that covers client identification and documentation of the beneficial owner.
3. Appoint an AML or compliance officer.
4. Train staff.
5. Report suspicions. Advisers who are not bound by attorney-client or notary-client privilege must report suspicions to the Money Laundering Reporting Office Switzerland (MROS). Advisers who are bound by that privilege do not have to report, according to the source.
6. Use the new transparency register. Advisers gain access to the register for due diligence purposes.

What it means for clients

Bär and Karrer expect clients to face earlier and more detailed requests for ownership, control-chain and transaction information, and warn that incomplete information may delay mandate acceptance, execution of transactions or access to services. That is a familiar pattern for anyone who has worked under the UK or EU rules. For the principles behind these checks, see our guides to ultimate beneficial ownership and KYC and customer due diligence for accountancy practices.

A practical preparation plan

1. Map your activities. List your engagements that involve non-operating entities or real estate and test them against the activities and thresholds above.
2. Choose an SRO early. The deadline for existing advisers is 1 December 2026, so allow time for the application.
3. Draft your onboarding concept. Decide how you will identify clients and document beneficial owners, and what happens if the client cannot or will not provide the information.
4. Name your compliance officer and plan training.
5. Set up reporting. Know how a suspicion moves from staff to the compliance officer and then to MROS, and where privilege applies.
6. Tell your clients. Explain that requests for ownership information are now a legal requirement.

Our overview of the FATF Recommendations explains why many countries are extending AML duties to advisers in this way.

Frequently asked questions

When does the revised Swiss AMLA take effect?

On 1 October 2026, according to Bär and Karrer.

What is the deadline for applying to an SRO?

Advisers already carrying out covered activities on 1 October 2026 must apply by 1 December 2026.

Does the Act cover all advice?

No. The rules focus on specified activities involving non-operating entities and real estate, and coverage is decided case by case.

Do lawyers have to report suspicions?

Advisers bound by attorney-client or notary-client privilege do not have to report suspicions to MROS, according to the source. Others do.

Next steps

If you advise on Swiss entities or property, start with the activity map and the SRO application. This article is general information, not legal advice. For further training on AML fundamentals, explore Learnsignal's CPD courses.