Until now, the Swiss Anti-Money Laundering Act (AMLA) applied mainly to banks, asset managers and other financial intermediaries. That changes on 1 October 2026. From then on, certain advisors must also meet due diligence obligations, regardless of whether they manage money themselves.
The legislator is targeting activities with an increased risk of money laundering: real estate transactions, companies without operating activities and domicile addresses. Anyone advising in one of these areas should check now whether they are affected.
It is the activity that counts, not the profession
The new law does not depend on job titles. Whether someone is a lawyer, notary, fiduciary, real estate advisor or management consultant makes no difference. What matters is what they do for their clients. A fiduciary firm that only keeps the books for SMEs, for example, is not automatically covered. The same firm may, however, be subject to the law as soon as it also sets up shell companies or offers domicile addresses.
These activities are newly covered
Real estate transactions
Covered is any involvement in the purchase or sale of real property, for example through negotiating, drafting contracts or supporting the transaction. This also applies to economically equivalent deals, such as selling a company that essentially holds a property.
Companies without operating activities
Newly covered is anyone who, on behalf of clients, – sets up, manages or administers companies without operating activities, – contributes capital to or distributes capital from such companies, – buys or sells companies through such structures, – sets up companies abroad.
This mainly affects providers who set up holding and shell companies or take over their administration.
Domicile and business address
Anyone who professionally provides a company with an address or premises as its registered office for more than six months is also covered. This affects classic domicile providers, but also virtual office providers offering a registered address.
When is the activity “professional”?
Only those who carry out these activities on a professional basis are covered. The ordinance sets thresholds for this. Professional activity exists if one of these values is exceeded within a calendar year:
| Criterion | Annual threshold |
|---|---|
| Gross revenue from covered activities | more than CHF 50,000 |
| Number of clients or transactions | more than 20 |
| Third-party assets advised on | more than CHF 5 million |
| Transaction volume | more than CHF 2 million |
A small fiduciary firm with 25 domicile clients is therefore already above the threshold.
The main exemptions
Not every mandate falls under the AMLA. Exempt are, among others:
- Smaller real estate transactions under CHF 5 million, if the purchase price is paid exclusively through a bank or another supervised financial intermediary.
- Family and inheritance matters, such as gifts or estate divisions.
- The purchase of owner-occupied residential property.
- Court and arbitration proceedings: lawyers remain exempt when representing clients in litigation.
- Pure notarisations by notaries without additional advice.
- Board or officer functions in operating companies and charitable foundations.
What affected persons must do from October
1. Join a self-regulatory organisation (SRO)
Covered advisors must join a recognised SRO. The application must be filed within two months of entry into force, i.e. by 1 December 2026. More about joining an SRO on our SRO licence in Switzerland page.
2. Identify clients
Before a mandate begins, the identity of the client and the beneficial owner must be established. This is where the AMLA and the Transparency Register interlock. How the 25% threshold works is explained in our article Who Is a Beneficial Owner?
3. Assess and document risks
The purpose and background of a transaction must be recorded. Where risks are higher, for example with complex structures or links to high-risk countries, additional clarification duties apply. Records must be kept for ten years.
4. Report suspicious cases
Where there is a well-founded suspicion of money laundering, there is a duty to report to the Money Laundering Reporting Office Switzerland (MROS). For lawyers, the reporting duty only applies if they carry out financial transactions for their clients themselves. Professional secrecy remains protected for purely advisory work.
5. Adapt internal organisation
Responsibilities, processes and staff training must be organised so that the obligations are met in day-to-day business.
What happens in case of violations?
Anyone who is covered but has not joined an SRO, or who breaches due diligence obligations, risks substantial fines. For intentional violations, amounts of up to CHF 500,000 are possible. On top of this come professional consequences and a considerable reputational risk.
Also relevant for entrepreneurs
The new obligations do not only affect advisors. Anyone founding a company, setting up a holding or taking a domicile address will be asked more often for IDs, ownership details and the source of funds. This is not harassment but a legal duty of the service providers. Having these documents ready gets you to your goal faster.
How to check whether you are affected
The question “Am I covered?” often cannot be answered in one sentence. A structured self-check with a clear assessment is available at gwgcheck.ch. For an overview of the whole legislative package, see our article Transparency Register and the New Anti-Money Laundering Act 2026.
FAQ
Am I automatically covered as an accountant or fiduciary?
No. Pure bookkeeping, tax advice and payroll administration for operating companies do not fall under the AMLA. What matters is whether you carry out one of the covered activities, for example administering shell companies or offering domicile addresses, and exceed the thresholds.
Does the new law also apply to existing mandates?
Yes. From 1 October 2026, due diligence obligations must also be met for existing client relationships, insofar as they involve covered activities. It is worth updating existing files early.
What is a company without operating activities?
A company that has no business operations of its own, i.e. no staff, no premises and no trading or production activity. Typical examples are pure holding or asset management companies.
Do I have to do anything as an entrepreneur using a domicile address?
You are not covered yourself. Your domicile provider must, however, verify your identity and the beneficial owners of your company. Expect them to request documents, even for existing contracts.
How are the AMLA and the Transparency Register connected?
Both enter into force on 1 October 2026. Covered advisors get access to the Transparency Register and must report if their information differs from the registered data. More at transparenzregister.ch.
Do you set up or manage companies in Switzerland? SWISS COMPANY AG supports you with incorporation, domicile and administration, with clean documentation under the new rules. More about administration in Switzerland
This article is for general information only and does not replace legal advice in individual cases.
