{"id":4400,"date":"2026-07-31T12:27:05","date_gmt":"2026-07-31T10:27:05","guid":{"rendered":"https:\/\/www.swisscompany.com\/?p=4400"},"modified":"2026-09-28T14:08:43","modified_gmt":"2026-09-28T12:08:43","slug":"revised-anti-money-laundering-act-switzerland-advisors","status":"publish","type":"post","link":"https:\/\/www.swisscompany.com\/en\/revised-anti-money-laundering-act-switzerland-advisors\/","title":{"rendered":"Revised Anti-Money Laundering Act: Which Advisors, Fiduciaries and Domicile Providers Are Now Covered"},"content":{"rendered":"\n

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<\/strong>. From then on, certain advisors must also meet due diligence obligations, regardless of whether they manage money themselves.<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

It is the activity that counts, not the profession<\/h2>\n\n\n\n

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<\/strong> 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.<\/p>\n\n\n\n

These activities are newly covered<\/h2>\n\n\n\n

Real estate transactions<\/h3>\n\n\n\n

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.<\/p>\n\n\n\n

Companies without operating activities<\/h3>\n\n\n\n

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.<\/p>\n\n\n\n

This mainly affects providers who set up holding and shell companies or take over their administration.<\/p>\n\n\n\n

Domicile and business address<\/h3>\n\n\n\n

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.<\/p>\n\n\n\n

When is the activity “professional”?<\/h2>\n\n\n\n

Only those who carry out these activities on a professional basis are covered. The ordinance sets thresholds for this. Professional activity exists if one<\/strong> of these values is exceeded within a calendar year:<\/p>\n\n\n\n

Criterion<\/th>Annual threshold<\/th><\/tr><\/thead>
Gross revenue from covered activities<\/td>more than CHF 50,000<\/td><\/tr>
Number of clients or transactions<\/td>more than 20<\/td><\/tr>
Third-party assets advised on<\/td>more than CHF 5 million<\/td><\/tr>
Transaction volume<\/td>more than CHF 2 million<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

A small fiduciary firm with 25 domicile clients is therefore already above the threshold.<\/p>\n\n\n\n

The main exemptions<\/h2>\n\n\n\n

Not every mandate falls under the AMLA. Exempt are, among others:<\/p>\n\n\n\n