Switzerland approves comprehensive anti-money laundering strategy with enhanced asset freezing measures
Switzerland's Federal Council has approved its first comprehensive national strategy on combating money laundering and terrorist financing, marking a significant evolution in the country's approach to financial crime prevention. Published on 20 March 2026, the strategy establishes a framework for strengthening Switzerland's position as a jurisdiction with robust integrity safeguards.
Strategic priorities and framework
The strategy pursues four core objectives: establishing an effective, risk-based, cooperative and innovative defence framework against money laundering and terrorist financing. It identifies four primary areas of action: prevention and supervision, investigation and prosecution, asset recovery, and terrorist financing.
Transparency register implementation
A central element of the strategy is the implementation of Switzerland's federal register of beneficial owners, which Parliament approved in September 2025. The transparency register is scheduled to become operational in the second half of 2026 and will provide authorised authorities and financial intermediaries with centralised access to accurate, complete and up-to-date information on beneficial owners of legal entities.
The register will be overseen by a new control body commencing work at the end of 2026. This body will ensure that entities subject to registration comply with their obligations and cannot conceal their beneficial owners.
Enhanced asset freezing and criminal prosecution
The strategy addresses what the Federal Council identifies as a key priority: facilitating the tracing and precautionary freezing of suspect assets. The Swiss authorities will examine how to accelerate the identification and freezing of potentially illicit funds, preventing their early withdrawal before confiscation proceedings can be completed.
Proposals are planned for targeted development of the criminal law basis to facilitate the prosecution and detection of money laundering. The measures aim to enable competent authorities to freeze suspicious assets more easily and quickly.
Strengthened supervision and due diligence
The strategy reinforces Switzerland's supervisory framework across multiple fronts. The Swiss Financial Market Supervisory Authority (FINMA) will continue its risk-based supervisory approach, with enhanced powers expected through the Too-Big-to-Fail legislative package planned for submission to Parliament by 2027.
Parliament's September 2025 amendments to the Anti-Money Laundering Act extended due diligence requirements to high-risk activities in the legal profession. Lawyers and notaries providing professional advice under certain conditions must now fulfil due diligence requirements and join self-regulatory organisations from 2026 onwards.
The amendments also strengthened due diligence requirements for cash payments in the trade of precious metals and real estate, addressing sectors identified as presenting heightened money laundering risks.
Risk-based approach and data consolidation
The strategy emphasises Switzerland's commitment to maintaining awareness of money laundering and terrorist financing risks at all times. Following the second national risk assessment in 2021 and sectoral assessments on cryptoassets (2024), proliferation financing (2024) and legal entities (2026), a comprehensive update of the national assessment is planned for 2026.
Statistical data already available across various authorities will be more closely linked, consolidated and jointly analysed. Data quality improvements will be pursued through the use of modern technologies.
International cooperation and technology
At international level, Switzerland reaffirms its commitment as a founding member of the Financial Action Task Force (FATF) to developing international standards and their uniform implementation worldwide. The Money Laundering Reporting Office Switzerland (MROS), as a member of the Egmont Group, works with 176 partner financial intelligence units to share financial information.
The strategy addresses both risks and opportunities presented by technological developments. MROS has adopted the goAML information system, which now receives over 96 per cent of suspicious activity reports electronically. From summer 2026, suspicious activity reports will only be submitted electronically, improving data quality and strengthening analytical capabilities.
Asset recovery and repatriation
Switzerland maintains its position as a leader in the repatriation of illegally acquired assets from politically exposed persons. The strategy confirms Switzerland's commitment to transparent restitution governed by clear procedures and core principles.
The Federal Council is examining how to further facilitate and accelerate the tracing and precautionary freezing of incriminated assets, with additional measures under consideration including amendments to the burden of proof requirements.
Implications for financial institutions and fiduciaries
The strategy has direct implications for financial intermediaries, trust companies and other regulated entities operating in or with Switzerland. The implementation of the beneficial ownership register will require affected companies to register their beneficial owners and maintain accurate records. Financial intermediaries will gain centralised access to this information for client due diligence purposes.
Enhanced supervision and strengthened sanctioning powers for FINMA and self-regulatory organisations signal increased regulatory scrutiny. Financial institutions should review their anti-money laundering frameworks to ensure alignment with evolving supervisory expectations.
The extension of due diligence requirements to legal professionals reflects a broader trend of expanding the regulated perimeter to address identified risks. Companies engaging legal advisers for transactions should be aware that these advisers may now have reporting obligations in certain circumstances.
Conclusion
Switzerland's comprehensive strategy represents a significant policy statement on the country's commitment to maintaining the integrity of its financial centre. For financial institutions, trust companies and corporate service providers, the strategy signals ongoing regulatory development and heightened supervisory expectations.
The strategy's publication provides clarity on Switzerland's policy direction over the coming years, enabling regulated entities to plan accordingly and ensure their operations remain compliant with one of the world's most sophisticated anti-money laundering frameworks.
