AMLA Revision 2026: Sanctions Compliance Explicitly Incorporated into the AMLA
Background
On 26 September 2025, the Swiss Federal Parliament adopted the revised Anti-Money Laundering Act (AMLA) as well as the Federal Act on the Transparency of Legal Persons (TJPA). The referendum period expired unused on 15 January 2026. Entry into force is expected during the second half of 2026.
The revision results in sanctions-related matters and proliferation financing being explicitly integrated into the anti-money laundering prevention framework. Consequently, the organisational requirements relating to sanctions compliance for financial intermediaries are being significantly specified and expanded.
Key Legislative Amendments
New Organisational Requirements
The revision specifies the organisational measures required to prevent sanctions violations.
These include in particular:
- conducting and regularly updating a sanctions and proliferation financing risk assessment;
- implementing and updating internal sanctions compliance policies;
- establishing appropriate screening and monitoring processes for business relationships and transactions;
- providing staff training regarding sanctions and circumvention risks;
- implementing documented escalation and reporting procedures.
The sanctions risk assessment may be integrated into the existing AMLA risk assessment.
Practical Implications
- Existing AMLA risk assessments should be expanded to include sanctions-related matters and proliferation financing.
- Compliance manuals, AML policies, and internal guidelines should be supplemented with explicit sanctions compliance requirements.
- Existing screening systems should be reviewed regarding completeness, timeliness, and response capability.
- Purely manual processes are likely to be viewed increasingly critically, particularly for larger or internationally active institutions.
- Internal escalation and decision-making processes relating to potential sanctions violations should be documented and traceable.
- Serious violations of the Embargo Act may result in anti-money laundering consequences and reporting obligations under Art. 9 AMLA. Existing reporting obligations towards SECO remain unaffected.

