Switzerland’s AML Overhaul in 2026: What Companies Must Prepare For

Switzerland is about to rewrite the rules of financial secrecy – again. From mid-2026, a new Federal Act on the Transparency of Legal Entities (LETA) and a revised Anti-Money Laundering Act (AMLA) will introduce a federal beneficial ownership register, tighter obligations for advisors, and more scrutiny on crypto flows. Parliament adopted the package in September 2025, with entry into force expected in the second half of 2026, aligned with Switzerland’s next FATF evaluation.

For boards, CFOs, and group counsel, this is not a marginal tweak. It fundamentally changes how corporate structures – including foreign holding vehicles – are documented, reported, and monitored.

What is changing in 2026

Beneficial ownership register

LETA creates a central, non-public Transparency Register of beneficial owners, administered electronically by the Federal Office of Justice and overseen by an audit unit at the Federal Department of Finance.

Almost all Swiss legal entities (AG, GmbH, cooperatives, SICAV/SICAF, limited partnerships for collective investments) and certain foreign entities with a Swiss nexus (branch, effective management in Switzerland, or Swiss real estate) will have to identify their ultimate beneficial owners (UBOs), verify them, and file the information with the register.

A beneficial owner is generally any natural person who ultimately controls at least 25% of the capital or voting rights, directly or indirectly, or otherwise exercises control through agreements or similar arrangements.

Stronger verification rules

Under LETA and its draft ordinance (LETO), companies must not only collect UBO data but also verify identity and the nature and extent of control, maintain evidence, and keep records up to date. Financial intermediaries will be obliged to report discrepancies between their own KYC information and the Transparency Register within 30 days. 

This is a clear shift from “internal list in a drawer” to a supervised, cross-checked federal system.

Enhanced obligations for intermediaries

The AMLA revision extends AML obligations to certain advisory and structuring activities – for example, high-risk work around real estate transactions, setting up or restructuring non-operational entities, and providing domicile/registered office services. Lawyers, notaries, trustees, and corporate service providers falling under the new “advisor” definition will need to join a recognised SRO, implement due diligence and reporting procedures, and file suspicious activity reports with MROS.

Intentional breaches of reporting duties can be punished with fines up to CHF 500,000; negligent breaches attract lower, but still material, sanctions.

Stricter corporate transparency

Internal UBO lists under the Code of Obligations will be phased out and replaced by the federal register regime. Listed companies and their >75%-owned subsidiaries, as well as pension institutions, are exempt; everyone else – roughly 600,000 entities – moves into a single, harmonised transparency framework.

Impact on foreign-owned companies & holding structures

The reforms matter just as much in Zurich boardrooms as in Luxembourg, Dubai, or Delaware – wherever groups run Swiss subsidiaries or use Switzerland for holding and asset-owning vehicles.

New BO reporting workflow

For in-scope entities, the basic workflow is:

1. Map ownership chains down to natural persons with at least 25% capital or voting rights, or other forms of control.
    
2. Collect verified ID data and evidence of control (shareholder registers, shareholder agreements, trust deeds, loan agreements, family links, etc.).
    
3. File UBO information electronically to the Transparency Register within one month of registration in the Commercial Register or becoming in-scope.
    
4. Update filings when control changes, again within one month.

Shareholders, quota-holders, and UBOs themselves also carry a one-month deadline to provide information to the company; failure to cooperate becomes a punishable offence. 

Deadline expectations and penalties

Existing companies will benefit from transitional periods, but these are expected to be measured in months, not years, and will depend on audit requirements and commercial register changes.

Intentional violations of reporting and cooperation duties can trigger fines up to CHF 500,000, with additional sanctions for advisors who ignore AMLA obligations or fail to report suspicious activity.

For foreign-owned groups with layered holdings, nominee arrangements, or private equity style structures, the cost of “wait and see” will be measurable – in remediation work, bank questions, and potential regulatory attention.

Crypto & digital asset AML updates

Switzerland has already been an early mover on crypto AML, and 2026 will further entrench that stance.

Virtual asset service providers (VASPs) are firmly in scope of the AMLA. FINMA guidance and AMLO-FINMA apply the FATF Travel Rule to blockchain transactions over CHF 1,000, requiring VASPs to collect and transmit originator and beneficiary information.

Key elements include:

• Full KYC and beneficial owner identification for customers of exchanges, brokers, and custodial wallets.
   
• Technical measures to prevent structuring – linked transactions designed to stay below the CHF 1,000 threshold over 30 days.
   
• Strict rules for self-hosted wallets: VASPs must verify that the customer controls the external wallet (e.g., via cryptographic proofs) and, for third-party wallets, identify the beneficiary and UBO.

For crypto businesses, the message is clear: Travel Rule implementation, real-time transaction monitoring, and wallet-ownership verification are no longer “nice to have” – they are core license and banking-relationship issues.

High-risk sectors that face greater scrutiny

While the framework is horizontal, some sectors will feel the heat first:

• Fintech and neobanks that operate with hybrid fiat-crypto models or cross-border customer bases.
• Investment firms and asset managers using SPVs, funds, and feeder structures that obscure UBOs.
• Multi-layer holding companies used for tax planning or asset protection, especially when combined with low-substance jurisdictions.
• International groups that centralise IP, treasury, or token ecosystems in Switzerland while operational activity is elsewhere.

For these, regulators and banks will be quick to test whether the Transparency Register data, internal UBO files, and bank KYC files actually tell the same story.

Preparing your corporate structure for 2026 requirements

Practical preparation now will cost far less than a rushed clean-up in 2026.

Documentation readiness

• Map every Swiss and Swiss-nexus entity, including dormant companies and property-owning vehicles.
• Build ownership charts down to natural persons, including indirect holdings and control via agreements.
• Standardise KYC packs: constitutional documents, shareholder registers, trust deeds, side letters, voting agreements.

Risk assessment

• Classify entities by AML risk: non-operational holding, high-risk geography, cash-intensive operations, crypto exposure.
   
• Identify structures that will be hard to explain to a bank or regulator and consider simplification before transparency becomes mandatory.

Governance controls

• Update board charters and internal policies to assign responsibility for UBO reporting and AMLA compliance.
   
• Implement periodic reviews (at least annually, plus event-driven) to refresh UBO data and test alignment between internal records, the Transparency Register, and bank KYC profiles.
   
• For crypto-active entities, integrate Travel Rule solutions, self-hosted wallet verification, and on-chain analytics into your compliance stack.

How SIGTAX helps

Navigating this shift is not just about filing forms; it is about aligning structure, substance, and transparency.

SIGTAX already advises international companies and groups on structuring Swiss entities with a clear rationale that meets AML, UBO, and cross-border reporting expectations, rather than simply “registering a company and hoping for the best.” 

In the 2026 context, that support extends to:

• BO registry compliance – mapping group structures, identifying UBOs, and preparing data in a format that can be reported efficiently to the Transparency Register.
   
• AML program setup – helping founders and advisors understand when their activities bring them under AMLA, and designing proportionate policies, training, and reporting workflows.
   
• Corporate structure mapping – stress-testing holding and financing chains against banks’ and regulators’ expectations, and recommending simplifications where opacity no longer pays.
   
• Crypto AML controls – aligning Travel Rule, KYC, and wallet-verification practices with Swiss expectations so that VASPs and crypto-active businesses can maintain banking access and regulatory comfort.

Final word

The headline for 2026 is simple: Switzerland is not abandoning its attractiveness as a financial centre – it is conditioning it on transparency. Companies that prepare their structures now will still benefit from Swiss stability. Those that don’t will experience the new AML reality through delayed bank accounts, remediation letters, and regulatory questions.