The reform implements recommendations issued by the Financial Action Task Force (FATF).
Historically, Swiss AML obligations primarily applied to financial intermediaries such as banks, payment institutions, crypto businesses and asset managers.
The new legislation expands the AML framework to certain professionals acting as "gatekeepers" to legal structures, corporate transactions and real estate transactions, even where they do not themselves hold client assets.
The objective is to increase transparency and reduce the misuse of legal entities and structures for money laundering and terrorist financing purposes.
Starting on 1 October 2026, Switzerland will introduce a new anti-money laundering framework for Advisors ("Berater").
For the first time, a wide range of professionals who are not financial intermediaries may become subject to AML obligations and SRO supervision. The new regime may apply to a broad range of professionals operating in Switzerland, including:
The key question is not your professional title but whether you assist clients with certain regulated transactions.
Many professionals are currently unaware that they may soon become subject to AML obligations despite never having been regulated before.
A common misconception is that the new regime applies to all advisory activities. This is not the case.
The AML obligations only apply when an Advisor professionally assists a client in connection with one of the specific transactions listed in the legislation (below). For example, pure general and abstract legal, tax, business or strategic advice without a sufficiently concrete transaction will generally not trigger AML obligations.
This distinction is particularly important for law firms, consultants, fiduciaries and family offices whose activities often include both regulated and non-regulated engagements.
However, an Advisor may become subject to AML obligations when professionally assisting third parties in connection with financial transactions relating to one of the following activities:
The AMLA defines non-operational entities broadly.
These include legal entities, companies, foundations, trusts, fiduciary structures and similar arrangements that are not established for the purpose of carrying out or supporting active commercial operations. Holding companies and passive investment structures may be examples. The legislation specifically identifies domicile companies as non-operational entities.
One of the most significant changes concerns domiciliation providers.
Any person or company that professionally provides registered office services, c/o addresses, virtual offices or company domiciliation services for more than six months may become subject to the AMLA.
Importantly, this rule applies independently from the concept of a non-operational entity.
In practice, this means that a provider may become regulated even where the domiciled company is fully operational and conducts active commercial activities.
Many business centres, fiduciaries and company service providers are expected to be affected by this change.
If your activities fall within the scope of the new legislation, you will generally need to:
In practice, this means introducing an AML framework similar to what many financial intermediaries already operate today, although generally in a simplified form.
In many cases, yes.
Advisors carrying out regulated activities on a professional basis will generally need to affiliate with a Swiss Self-Regulatory Organisation (SRO). The purpose of the SRO is to supervise compliance with AML obligations and ensure that adequate internal controls are implemented.
No.
This distinction is important.
Many professionals immediately assume that the new rules will place them in the same category as payment institutions, crypto businesses, lending providers or commodity traders.
This is not the case.
The new legislation creates a separate category of regulated persons called Advisors (Berater).
Although Advisors will generally need to affiliate with an SRO, the regime is expected to be substantially lighter than the framework applicable to traditional financial intermediaries.
Based on discussions with several Swiss SROs, dedicated onboarding procedures for Advisors are currently being developed and are expected to be:
than traditional SRO applications for financial intermediaries.
The regime has not yet entered into force and practical experience remains limited.
However, based on existing discussions with Swiss SROs, businesses that are already established and operating in Switzerland should generally expect a process measured in weeks rather than months.
For most Advisors, an affiliation timeline of approximately two to four weeks appears realistic, assuming documentation is readily available.
Once the legislation enters into force, businesses performing regulated activities without complying with the applicable AML requirements may expose themselves to regulatory and legal risks, including criminal investigation.
For this reason, many fiduciaries, consultants, family offices and corporate service providers are already beginning to assess their position ahead of October 2026.
At SynHedge, we assist professionals and businesses in determining whether the new Advisor regime applies to their activities and, where necessary, guide them through the entire compliance process.
Our services include:
Whether you are a fiduciary, lawyer, consultant, family office, real estate professional or domiciliation provider, we can help you prepare efficiently for the new Swiss AML framework.
In many cases, yes. Fiduciaries are among the professions most likely to be affected because they frequently provide company formation, administration, domiciliation and corporate structuring services that fall within the scope of the new legislation.
Potentially. A MFO may become subject to AML obligations if it assists clients with transactions covered by the legislation, such as holding structures, company formations, acquisitions or non-operational entities. A case-by-case analysis is required.
Generally yes. The formation or establishment of non-operational legal entities in Switzerland or abroad is specifically listed as a regulated activity under the revised AMLA. However it remains unclear at the moment how to assess whether a company will be operational or not at the time of incorporation.
Yes. Businesses providing registered office services, c/o addresses or virtual office services for more than six months may become subject to AML obligations and may need to affiliate with an SRO. This applies regardless of whether the company is an operating or non-operating company.
This is one of the most significant changes introduced by the reform.
Generally, no. The legislation focuses primarily on non-operational entities.
However, domiciliation services may be regulated even when the company receiving the address is fully operational.
No. The revised AMLA creates a separate category of regulated persons called Advisors (Berater /Conseillé).
Although Advisors may require SRO affiliation, they are not automatically classified as financial intermediaries.
Financial intermediaries typically accept, hold, manage or transfer third-party assets. Examples include payment institutions, crypto businesses, lending companies and asset managers.
Advisors generally assist clients with specific transactions but do not themselves handle client assets. The compliance requirements for Advisors is to some extend lighter than those applicable to financial intermediaries.
No. Only consultants performing regulated advisory activities listed in the law on a professional basis may become subject to SRO affiliation requirements.
This is not formally mandatory. However, in practice, businesses subject to the new regime should implement written AML policies, internal procedures, onboarding processes and risk assessment frameworks and ensure a proper organisational framework.
Advisors may be required to submit a report to MROS when they know or have reasonable grounds to suspect that a transaction involves money laundering, criminal assets or terrorist financing.
Special rules apply to lawyers and notaries.
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Copyright © SynHedge LLC - 2026
Copyright © SynHedge LLC - 2026