Switzerland’s AML rules for advisers are confirmed: the focus now turns to implementation

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Switzerland’s AML rules for advisers are confirmed: the focus now turns to implementation

Published on
July 6, 2026

On 12 June 2026, the Swiss Federal Council confirmed that the revised Anti-Money Laundering Act (AMLA) and the new Act on the Transparency of Legal Persons, known in German as the TJPG, will enter into force on 1 October 2026. Both were passed by Parliament in September 2025, and the implementing ordinances are now settled. The period of legislative uncertainty is over. For trustees, fiduciaries and corporate service providers, the question is no longer what the rules will say, but how to be ready for them.

What changes for advisers

The development that matters most for our sector is the extension of AMLA to certain advisory activities that previously sat outside its scope. The regime is aimed at higher-risk structuring and transaction work rather than ordinary professional advice. The activities expected to fall within scope include:

  • Forming, structuring and restructuring non-operating entities.
  • Providing registered offices and domiciliation services.
  • Managing or administering non-operating entities.
  • Arranging capital contributions and distributions.
  • Handling acquisitions and disposals involving non-operating entities.

Where these activities are carried out on a professional basis, the adviser becomes subject to anti-money laundering obligations for the first time.

The new obligations

Firms brought into scope will need to apply the core AMLA duties that financial intermediaries already know well:

  • Identifying clients and their beneficial owners.
  • Documenting the purpose and background of transactions.
  • Maintaining internal controls and staff training.
  • Reporting suspicions to the Money Laundering Reporting Office Switzerland (MROS).
  • Affiliating with a recognised self-regulatory organisation (SRO).

The obligations carry weight. Intentional breaches of the reporting duties can attract fines of up to CHF 500,000.

The transparency register

Running in parallel is the new federal transparency register, which records the beneficial owners of Swiss legal entities. Most companies will need to identify and report their beneficial owners within set transition periods after the rules take effect. Advisers and financial intermediaries will be able to consult the register when carrying out their own due diligence, which over time should make verification more straightforward.

A short window to act

The timetable is tight. Advisers who are in scope when the rules take effect will have a short period, understood to be two months, to affiliate with an SRO or notify the relevant supervisory body. One point is worth noting for established trust companies. A firm already affiliated with an SRO as a financial intermediary is expected to remain under that same SRO for its advisory work, which avoids fragmented supervision and reduces the administrative burden.

From monitoring to implementation

Until now, much of the work for affected firms has been watching the legislative process. That phase has ended. The practical tasks are now clear:

  • Analysing which activities fall within scope.
  • Mapping services against the new obligations.
  • Reviewing client onboarding and due diligence procedures.
  • Documenting risk assessments and internal controls.
  • Preparing staff training.
  • Arranging SRO affiliation where required.

For families and businesses that hold or use Swiss structures, the regime also adds a layer of compliance to how those structures are administered day to day.

How Alpadis can help

Alpadis Trust (Switzerland) operates as a FINMA-licensed trustee in Zurich and understands these obligations from the inside. As the new rules take effect, the entities and structures we administer will continue to be managed in line with the updated framework, and we can help clients whose arrangements are affected work through what the changes mean in practice, from scope analysis to the supporting compliance processes. As an independent firm with no ties to banks, law firms or investment managers, our focus is on sound governance and getting the structure right.

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