Partial Revision of the AMLO-FINMA, AMLA Revision and Transparency Register
The Regulatory Roadmap
On 12 May 2026, FINMA opened the consultation on the partial revision of the FINMA Anti-Money Laundering Ordinance. The consultation lasted until 9 June 2026. The need for revision arises from amendments to higher-level anti-money laundering legislation, the implementation of FATF recommendations and clarifications of existing supervisory practice. The partially revised AMLO-FINMA is expected to enter into force on 1 January 2027.
In parallel, on 12 June 2026, the Federal Council decided that the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, as well as the revision of the Anti-Money Laundering Act, will enter into force on 1 October 2026. The originally planned entry into force on 1 July 2026 was postponed in order to give the affected parties more time for implementation.
Key Topics
The regulatory developments concern in particular the transparency of beneficial owners, the introduction of a central federal transparency register, the stronger integration of sanctions and embargo risks into the AML framework, organisational measures to prevent sanctions violations and the exchange of data between authorities. In addition, the scope of application of the AMLA will be extended to certain advisory services, namely in connection with real estate transactions and the establishment, structuring or administration of companies.
Sanctions Compliance
The AMLA revision and the partial revision of the AMLO-FINMA strengthen the organisational requirements in the area of sanctions and embargoes. Financial intermediaries must take appropriate measures to prevent violations of coercive measures under the Embargo Act. These include in particular risk analyses, internal policies, risk-based screening processes, escalation channels, documentation and employee training.
The AML risk analysis should in future also adequately cover sanctions, embargoes, proliferation financing and circumvention risks. It should also be assessed whether contracting parties, beneficial owners, controlling persons and authorised representatives are screened against relevant sanctions lists on a risk-based and timely basis.
Traceability of Ownership and Control Structures
Another focus area concerns the traceability of ownership and control structures. Financial intermediaries must be able to understand who ultimately owns or controls the contracting party, particularly in the case of domiciliary companies and complex structures. The ownership and control relationships must be documented in a reproducible manner. In addition, the economic reasons for the structure and the relationships between the companies involved should be understood and documented.
Transparency Register
The new transparency legislation introduces a central federal transparency register for beneficial owners. Legal entities must report their beneficial owners. Financial intermediaries will be able to access register data in the future for the purpose of fulfilling their due diligence obligations, although there is no general obligation to consult the register. Where discrepancies are identified between register data and the institution’s own documentation, corresponding clarification and, where applicable, reporting processes must be observed.
Action Points
- Review AML policies and sanctions compliance requirements;
- supplement the AML risk analysis to include sanctions, embargoes, proliferation financing and circumvention risks;
- review KYC checklists for the identification of beneficial owners;
- document complex ownership and control structures in a comprehensible manner;
- review screening frequency and responsiveness to new sanctions lists;
- define escalation processes for potential sanctions or structural red flags;
- train employees on sanctions, embargoes and circumvention risks;
- prepare for the transparency obligations from 1 October 2026;
- monitor the final wording of the partially revised AMLO-FINMA with a view to its planned entry into force on 1 January 2027.
