The case
The Swiss Financial Market Supervisory Authority (FINMA) has launched a consultation on the partial revision of the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA). The consultation period ends on 9 June 2026.
Source: FINMA
The commentary
The revision of the AMLO-FINMA has become necessary in the wake of amendments to the Swiss Anti-Money Laundering Act, the implementation of recommendations issued by the Financial Action Task Force (FATF) and the need to codify certain aspects of current supervisory practice.
The AMLO-FINMA sets out how financial intermediaries must implement their obligations relating to the prevention of money laundering and terrorist financing.
Under the proposed revisions, financial intermediaries will be required to obtain a clearer understanding of the ownership and control structure of their clients. The revised provisions also specify in greater detail the measures that financial intermediaries must implement in order to prevent breaches of coercive measures enacted under the Embargo Act.
In the context of correspondent banking relationships, the draft revisions provide that, in the case of payable-through accounts, financial intermediaries may only execute transactions on behalf of their customer’s clients if it is ensured that the customer will, upon request, provide the client information required to fulfil due diligence obligations.
Furthermore, a declaration regarding the beneficial owner must also be obtained where a contracting party maintains sub-accounts for individual clients. For more information see link.
