Frequently asked questions
Answers on AMLA obligations and practical implementation
Detailed explanations of the revision, affected activities, use of the checks and possible obligations.
Basics and applicability
What is the Anti-Money Laundering Act?
The Anti-Money Laundering Act is intended to prevent assets originating from criminal offences from entering the legitimate economy or being used to finance terrorism. It requires certain companies and professionals to carry out identification, clarification, documentation and organisational measures.
When does the AMLA revision enter into force?
The revised Anti-Money Laundering Act and the new Act on the Transparency of Legal Entities enter into force on 1 October 2026. Special transitional timing applies to certain provisions concerning official notariats.
Who may be newly affected by the revision?
Companies and professionals who carry out certain higher-risk transactions professionally may be newly affected. This includes in particular selected real estate transactions and services relating to the formation, structuring, management or transfer of certain legal entities.
Are all fiduciary and advisory firms subject to the AMLA?
No. The industry label alone does not determine applicability. The decisive factors are the services actually provided, the role in the transaction, whether the activity is carried out professionally and any statutory exceptions.
Which activities do the checks cover?
The checks cover in particular payment services, the safekeeping or management of securities, certain real estate transactions, services relating to non-operating legal entities, selected company transfers and longer-term domiciliation services.
Is every real estate transaction relevant under the AMLA?
No. The decisive factors are the type of involvement, the service provider’s role and any applicable exceptions. The transaction check asks, among other things, about situations under family, inheritance, gift and agricultural law and about purely notarial certification without additional advice.
Do transactions below CHF 5 million automatically qualify for an exception?
No. The value alone is not sufficient. The other requirements must also be met, in particular the rules governing the payment method through banks or other financial intermediaries subject to the AMLA.
What is a non-operating legal entity?
This refers to legal entities that do not serve to operate or support an operating business activity of a company or group. They may include in particular domiciliary companies or pure holding and asset structures.
When is an activity considered to be carried out professionally?
An activity is carried out professionally if it is performed independently and is intended to generate income on an ongoing basis. In addition, thresholds apply to gross revenue, number of clients, number of legal transactions, assets concerned and transaction volume.
Which thresholds are taken into account?
The basis of the check refers to more than CHF 50,000 in gross revenue, more than 20 clients, more than 20 legal transactions, third-party assets exceeding CHF 5 million or a transaction volume exceeding CHF 2 million per calendar year.
Are lawyers and notaries automatically affected?
No. Activities connected with court, criminal, administrative or arbitration proceedings are subject to specific distinctions. What matters is the specific service provided within or outside such proceedings.
Questions about using the checks
Is the result of the check binding?
No. The check provides a non-binding initial assessment based on the information entered. It does not replace legal advice or a professional review of the specific business model.
What happens if I cannot answer a question?
Select “Not sure”. The check will then not produce an artificially positive or negative result, but will indicate that a clear assessment is not possible on the basis of the information provided.
Do I have to provide my email address?
No. The short result is displayed without an email address. An email address is only required if you wish to receive the detailed result or subscribe to specialist information.
Are my answers to the check stored?
The answers are processed to calculate the result and, on request, to send the result once. They are not stored in WordPress as a complete check file and are not transferred to Brevo.
Do the checks cover every possible case?
No. The checks cover selected activities and situations. Other grounds for applicability, special rules or particular circumstances may fall outside the scope of the assessment.
Which legal position do the checks reflect?
The checks reflect the provisions applicable from 1 October 2026. The applicable legal provisions and the specific circumstances remain decisive.
Obligations and practical implementation
Which obligations may arise if the AMLA applies?
Depending on the type of applicability, obligations may include affiliation with a self-regulatory organisation, appointment of an AMLA officer, preparation of regulations and directives, identification of the contracting party, identification of the beneficial owner, sanctions-list screening, risk assessment, additional clarifications, file management, ongoing updates, internal controls and defined reporting procedures, self-declarations and audits.
Does every client have to be checked?
Not every business relationship is automatically subject to the same obligations. However, for a covered business relationship, the prescribed identification and clarification steps must be completed and documented.
What is a beneficial owner?
This is the natural person who actually controls or economically benefits from a company, structure or assets. This person may differ from the formal contracting party or a person entered in the commercial register.
What belongs in an AMLA file?
A file typically contains information on the contracting party and beneficial owner, identification documents, information on representation and beneficial ownership, information on the purpose and background of the business relationship, the risk classification, additional clarifications, decisions and evidence of subsequent updates.
Must client data be updated regularly?
Yes. The documents must remain current and traceable. Changes in ownership, governing bodies, business activities, payment methods or risk indicators may trigger a new review or update.
What are higher-risk business relationships?
Higher risks may arise, for example, from politically exposed persons, higher-risk countries, unusually high asset values, complex structures or payment methods that are difficult to understand. Such cases require more detailed clarification and a documented decision.
Must an affected company affiliate with an SRO?
This depends on the specific activity and the applicable supervisory model. If applicability is confirmed, it must be determined which supervisory organisation is responsible and which deadlines and admission requirements apply.
When may a report to the Money Laundering Reporting Office Switzerland (MROS) be required?
A substantiated suspicion of money laundering or terrorist financing may trigger a reporting obligation to the Money Laundering Reporting Office Switzerland (MROS). The assessment requires a documented internal process and, where appropriate, a professional or legal review of the individual case.
How is the transparency register connected to the AMLA?
The transparency register records the beneficial owners of certain legal entities. It forms part of strengthened anti-money laundering measures but constitutes an independent statutory obligation.
What should a potentially affected company do now?
Map the services offered and business processes, identify activities that may be covered, and assess whether the professional activity criteria and exceptions apply. If the AMLA applies, implement the required obligations (see “Which obligations may arise if the AMLA applies?”). Clarify how you will meet your documentation obligations. It may be useful to use a suitable platform. In unclear cases, an individual assessment is advisable.