The Swiss Financial Market Supervisory Authority (FINMA), the country’s financial markets watchdog, has finalised a partial overhaul of its Anti-Money Laundering Ordinance.

This places fresh compliance obligations on banks, insurers and advisers as Switzerland prepares for its next FATF mutual evaluation.

The updated ordinance, known as AMLO-FINMA, reflects recent changes to the Anti-Money Laundering Act (AMLA) and to the Federal Council’s own Anti-Money Laundering Ordinance (AMLO). Both were amended with the upcoming FATF assessment in mind.

FINMA’s Board of Directors has also approved two revised self-regulatory frameworks as minimum standards. The first is the agreement on the Swiss banks’ code of conduct on due diligence. The second is the rulebook of the Self-Regulatory Organisation of the Swiss Insurance (SRO-SVV). The ordinance and both frameworks take effect on 1 January 2027, and each set of self-regulation gives firms four months to transition.

The final text follows a consultation process, and feedback from that process changed the rules on correspondent banking relationships with foreign institutions. FINMA has now made clear that Article 37 para. 5 AMLO-FINMA covers only clients who can access the correspondent bank’s accounts directly.

Respondents also asked the regulator to clarify a range of individual provisions, and some of these points now appear in the explanatory notes. The guidance on transparency of ownership and control structures now explains how this provision works alongside the rules on complex structures and domiciliary companies.

It also sets out the risk-based approach and the documentation firms must keep. In addition, the notes on new measures to stop breaches of coercive measures under the Embargo Act now explain in more detail how the provision on monitoring business relationships and transactions applies by analogy.

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