FINMA Proposes AML Overhaul With Sharper Focus on Ownership Structures & Sanctions Controls

Key Takeaways

• FINMA Opens AML Consultation: Swiss Financial Market Supervisory Authority has launched a consultation on revisions to its Anti-Money Laundering Ordinance, with the process running through June 9, 2026.
• Ownership Transparency Takes Center Stage: The proposed changes would require financial intermediaries to better understand customer ownership and control structures as part of enhanced due diligence obligations.
• Sanctions Controls Formalized: The revisions would clarify expectations around measures firms must implement to prevent breaches of coercive measures under Switzerland’s Embargo Act.
• Correspondent Banking Oversight Tightened: Financial intermediaries handling transitory accounts would only be allowed to execute payments if underlying client information can be provided upon request to satisfy due diligence requirements.

Deep Dive

Switzerland’s financial regulator is proposing a fresh round of anti-money laundering reforms that would sharpen expectations around customer transparency, correspondent banking oversight, and sanctions compliance as global pressure on financial crime controls continues to mount.

The Swiss Financial Market Supervisory Authority opened a public consultation on a partial revision of its Anti-Money Laundering Ordinance, known as AMLO-FINMA. The consultation will remain open until June 9, 2026, with the revised framework expected to take effect on January 1, 2027.

The changes are aimed at aligning the ordinance with recent amendments to Switzerland’s Anti-Money Laundering Act while also incorporating recommendations stemming from the country’s latest evaluation by the Financial Action Task Force (FATF). FINMA said the revisions are also intended to formally codify supervisory practices that have increasingly become part of day-to-day oversight.

At the heart of the proposal is a stronger emphasis on understanding who ultimately owns and controls customers.

Under the revised rules, financial intermediaries would be expected to demonstrate that they can understand the ownership and control structure of a contracting party as part of their due diligence obligations. The proposal reflects a broader international push toward greater transparency around beneficial ownership structures, an area regulators worldwide have increasingly identified as critical in combating money laundering, terrorist financing, and sanctions evasion.

FINMA is also seeking to formalize expectations tied to sanctions-related risk management under Switzerland’s Embargo Act.

While firms supervised by FINMA are already expected to identify and manage risks associated with sanctions regimes under general risk management principles, the regulator said amendments to the Anti-Money Laundering Act now explicitly require organizational measures aimed at preventing breaches of coercive measures under the Embargo Act. The revised ordinance would clarify those expectations through a newly introduced provision detailing the controls financial intermediaries are expected to maintain.

The consultation package also takes aim at correspondent banking arrangements and so-called payable-through or transitory accounts, areas long viewed by regulators as vulnerable to abuse because of the opacity that can exist between institutions and underlying clients.

Under the proposed revisions, financial intermediaries would only be allowed to execute payments on behalf of a customer’s clients if they can ensure the customer will provide the necessary client information upon request so due diligence obligations can be fulfilled. FINMA said the measure formally embeds its long-standing supervisory practice around verifying the completeness of payment orders and ensuring required information can be traced through correspondent banking chains.

Another proposed clarification centers on sub-accounts maintained for unnamed or individual clients. FINMA said financial intermediaries would be required to obtain a declaration identifying the beneficial owner even in those cases, reinforcing requirements already established under Switzerland’s anti-money laundering legislation.

The proposal would also repeal a provision concerning payments to and from Liechtenstein that had previously treated those transactions similarly to domestic payments where the full payment data set was not transmitted. FINMA said the rule became obsolete following the introduction of QR-code payment systems in 2020, which now allow full payment data to be transmitted.

Beyond the substantive compliance measures, the consultation includes several technical and structural amendments to the ordinance itself, including updated references to recognized self-regulatory frameworks such as the Swiss Bankers Association’s due diligence code, known as CDB 20, and the rulebook of the Swiss Insurance Association’s self-regulatory organization.

The revised ordinance is scheduled to enter into force alongside updates to those self-regulatory standards at the start of 2027, which is another step in Switzerland’s ongoing effort to adapt its financial crime framework to evolving international expectations and supervisory realities.

The GRC Report is your premier destination for the latest in governance, risk, and compliance news. As your reliable source for comprehensive coverage, we ensure you stay informed and ready to navigate the dynamic landscape of GRC. Beyond being a news source, the GRC Report represents a thriving community of professionals who, like you, are dedicated to GRC excellence. Explore our insightful articles and breaking news, and actively participate in the conversation to enhance your GRC journey.