Switzerland’s AML rules change on 1 October 2026. The bigger challenge may be where the file lives

Take a UK firm with a Geneva or Zurich office. On 1 October 2026, the AML rules governing that office changed. This is not the EU Anti-Money Laundering Regulation. It is Switzerland's own reform: a revised Anti-Money Laundering Act and a new federal transparency law, both in force on the same day.

A client spanning the UK, the EU and Switzerland is one file governed by three rulebooks.

This is a Swiss reform, not an extension of the EU AMLR

Switzerland is not part of the EU, and the EU AMLR does not apply there. The changes instead come from two Swiss instruments taking effect on the same day: the revised Anti-Money Laundering Act and the new Federal Act on the Transparency of Legal Entities.

The new transparency law creates a central register of beneficial owners. It will not be publicly accessible. The register will be administered by the Federal Office of Justice, with access limited to Swiss authorities, AML supervisors and professionals carrying out due diligence.

Swiss legal entities, and foreign entities with specified Swiss connections, such as a Swiss branch, effective management in Switzerland or ownership of Swiss real estate, will need to report the natural persons who control 25% or more. New information must generally be filed within 30 days, while existing entities will have transitional periods of up to six months. Intentional breaches may result in fines of up to CHF 500,000.

For international firms, the register creates new information and filing requirements. The revised AML framework has a more fundamental effect: it may bring previously unregulated advisory work within scope.

Some advisory work will become subject to AML requirements

Historically, Swiss advisers, lawyers and notaries have generally sat outside the AML framework unless they were acting as financial intermediaries. From 1 October 2026, specified advisory activities will also be brought within scope.

The distinction turns on the work being performed, rather than the adviser’s title. AML obligations may apply where a lawyer or other adviser is involved in activities such as:

• designing or structuring companies or asset-holding arrangements;
• forming or administering legal entities;
• acting in board, fiduciary or nominee roles; or
• providing a registered office or business domicile.

Pure legal advice, litigation and defence work remain outside scope. The practical dividing line is between advising a client on a structure and helping to establish, administer or operate it.

The reform also removes the CHF 100,000 cash threshold, with particular implications for transactions involving real estate. Firms undertaking activities within the scope will need to affiliate with a self-regulatory organisation and meet the associated requirements. These include identifying the client and beneficial owner, understanding and documenting the background to the relationship, conducting ongoing monitoring and retaining records for ten years.

For international firms, that final requirement is not simply a retention question. It is also a systems and data-location question.

A foreign-hosted system may not be enough on its own

Swiss AML record-keeping requirements address both what must be retained and where the information must be available.

Under the FINMA Anti-Money Laundering Ordinance, records must be kept in a secure location in Switzerland and remain accessible at all times. Where the primary server is located abroad, up-to-date copies of the relevant documents must be maintained in Switzerland (AMLO-FINMA, Article 74). The records must generally be retained for ten years (AMLA, Article 7).

This does not necessarily mean that every system must be hosted exclusively in Switzerland. A primary copy may be held elsewhere. But access from a Swiss office to a web/cloud-based platform hosted abroad may not, by itself, satisfy the requirement to maintain an up-to-date copy in Switzerland.

That distinction creates an operational question for firms using case-management, client-onboarding or identity-verification platforms with servers hosted outside Switzerland: how will a current Swiss copy of every relevant file be created and maintained?

Without an automated process or an integration, firms may need to transfer completed files through an API or download and store them manually. Either approach can work, but manual processes create predictable gaps: a file is not exported, a later update is missed, or the locally held copy no longer matches the live record.

The stronger approach is to make the Swiss copy part of the workflow, with a clear audit trail showing what was retained, where it was stored, who was involved in the file and when it was last updated.

Make the design decisions before the deadline

The requirements are manageable, but they may be difficult to retrofit close to implementation.

Firms should establish:

• which Swiss mandates will fall within the expanded AML perimeter;
• where the associated records are currently hosted;
• whether remote access meets the applicable record-keeping requirements;
• how an up-to-date Swiss copy will be created and maintained; and
• whether the process can be automated within existing onboarding and case-management workflows.

The detailed obligations for firms supervised by self-regulatory organisations will continue to develop as implementing ordinances and Self-regulatory Organisation (SRO) rules are finalised. But firms do not need to wait before mapping affected work, reviewing their data architecture and identifying where manual processes would otherwise be required.