FINMA Anti-Money Laundering Ordinance: 2027 Deadline

The Swiss Financial Market Supervisory Authority (FINMA) published a partially revised anti-money laundering ordinance on November 10, 2026, setting January 1, 2027 as the date supervised firms must comply with stricter due diligence rules ahead of Switzerland’s next international assessment.

The revised FINMA anti-money laundering ordinance (AMLO-FINMA) gives banks, asset managers, insurers and other supervised intermediaries about seven weeks to adjust. It follows a consultation that FINMA opened on May 12 and closed on June 9, 2026.

FINMA anti-money laundering ordinance: what was finalized

FINMA said the revision reflects recent changes to the Anti-Money Laundering Act (AMLA) and to the Federal Council’s own Anti-Money Laundering Ordinance. It also takes account of the forthcoming Financial Action Task Force (FATF) mutual evaluation of Switzerland, in which the global standard-setter tests how well a country applies its rules.

“The Ordinance and both sets of self-regulation will come into force on 1 January 2027,” FINMA said in its press release.

FINMA’s Board of Directors also recognized two industry texts as minimum standards. They are the revised Swiss banks’ code of conduct on due diligence, known as VSB 27, and the revised rules of the Self-Regulatory Organisation of the Swiss Insurance (SRO-SVV).

Each of the two self-regulation texts has a four-month transition period. FINMA’s release states no separate transition for the ordinance itself.

What changes in the FINMA anti-money laundering ordinance

The revision touches several provisions. The consultation draft and FINMA’s key points identify the main ones, and the final text keeps them.

Ownership and control structures. A new Article 9b requires intermediaries to understand the structure of ownership and control behind a contracting party. FINMA says this codifies existing supervisory practice.
Embargo Act breaches. Article 1 para. 1 now lists the prevention of breaches of coercive measures under the Embargo Act as an object of the ordinance. A new Article 30 sets out the related measures, applying the rules on monitoring business relationships and transactions by analogy.
Correspondent banking. Article 37 is revised. For payments made on behalf of a counterparty’s clients, intermediaries may act only if the counterparty provides the required client information on request.
Sub-accounts. A new letter d in Article 65 para. 2 requires a declaration of the beneficial owner where a contracting party keeps sub-accounts for individual clients.
Liechtenstein payments. Article 10 para. 3 is repealed, ending the reduced data set for transfers to and from Liechtenstein, which now count as cross-border payments.

The revised AMLA provisions behind the Embargo Act measures are Articles 1 and 8 of the Act. The Federal Council set the wider AMLA reform to take effect on October 1, 2026.

Changes made after consultation feedback

Feedback led FINMA to amend the correspondent banking rule. Article 37 para. 5 AMLO-FINMA now covers only clients who can access the correspondent bank’s accounts directly, which narrows what the first draft appeared to catch.

FINMA also expanded its explanatory notes in two places. The notes on transparency of ownership and control structures now explain how that provision works with the rules on complex structures and domiciliary companies. They also describe the risk-based approach and the records firms must keep.

The notes on the Embargo Act measures give more detail on how the monitoring rules apply by analogy. For sanctions teams, that clarifies how far existing transaction monitoring setups can be reused for embargo controls.

Advisory services and the scope of supervision

The revised AMLA extends due diligence duties to certain advisory services, such as help with founding, managing or structuring companies and trusts. Lawyers, notaries, fiduciaries, asset managers and real estate brokers are among the professions concerned, with core activities such as conducting litigation exempt.

That forced a change to FINMA Circular 2011/1 on acting as a financial intermediary under the AMLA. FINMA has issued standalone guidance, 06/2026, that defines the circular’s scope and clarifies which bodies supervise advisory activities.

The ordinance applies to financial intermediaries under Article 2 para. 2 AMLO-FINMA. That covers banks, securities firms, portfolio managers and trustees, among others. Insurers fall under the SRO-SVV rules, which take effect on the same date. The consolidated ordinance is on Fedlex.

What the ordinance means for compliance teams

The rules set out the tasks. For ownership structures, firms must be able to show they understand who stands behind a client, and FINMA’s notes tie that to records kept under a risk-based approach. That bears on customer due diligence files and on cases that call for enhanced due diligence, such as complex structures and domiciliary companies.

For sanctions, the ordinance expects measures against Embargo Act breaches that include monitoring of business relationships and transactions. For banks that act as correspondents, the Article 37 changes mean payment flows for respondent banks’ clients depend on information being available on request.

Firms that hold sub-accounts for individual clients under a contracting party need a beneficial owner declaration for them. Existing procedures, forms and system rules may need updating to produce these records.

The wider anti-money laundering framework still rests on the firm’s own program. Teams reviewing theirs can use the AML and KYC program template pack as a checklist for policies, risk classification and documentation.

The articles in the ordinance apply from January 1, 2027. The four-month transition covers only the banks’ code of conduct and the SRO-SVV rules, so firms relying on those texts have a longer runway than those measuring against the ordinance alone.

Why the FINMA anti-money laundering ordinance matters for FATF

Switzerland was last assessed by the FATF in 2016, and the FATF has since published follow-up reports. The country’s fifth-round review is expected in 2027, and the Federal Council’s transparency register for beneficial owners and the extension of the AMLA to advisers are both part of the preparation.

The ordinance is the layer that governs how FINMA-supervised firms apply those laws day to day. Assessors test whether rules are applied in practice, so firms’ client files, sanctions controls and correspondent banking records are likely to be where gaps show.

FINMA’s release gives no date for the evaluation. The next fixed date for firms is January 1, 2027, when the ordinance, VSB 27 and the SRO-SVV rules begin to apply.