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Swiss AML & KYC Requirements

Anti-money laundering obligations for Swiss companies

Swiss AML Framework

Switzerland's Anti-Money Laundering Act (AMLA/GwG) imposes obligations on a broad range of financial intermediaries and, increasingly, on non-financial businesses. Switzerland is a FATF member and maintains high compliance standards.

Who Is Subject to AMLA

  • Banks and financial institutions (fully regulated by FINMA)
  • Securities dealers and portfolio managers
  • Money services businesses (currency exchange, payment services)
  • Notaries and fiduciaries (for certain transactions)
  • Real estate agents (for transactions over CHF 100,000)

For Standard Swiss Companies

A typical GmbH operating as a trading company is not itself a financial intermediary and is not directly subject to AMLA. However, it must maintain records of beneficial owners and cooperate with investigations.

UBO Register (SESTA)

Since 2022, Swiss companies must maintain an internal register of all beneficial owners (persons who ultimately own or control >25%). This register must be updated within one month of any change and made available to authorities on request.

Practical AML Obligations

  • Know your significant customers and suppliers (basic KYC for high-value transactions)
  • Be vigilant for suspicious transaction patterns
  • Maintain transaction records for 10 years
  • Report suspicious activity to the Money Laundering Reporting Office Switzerland (MROS)