On 26th of September 2025 the Swiss Parliament passed the revised Anti-Money Laundering Act (AMLA) and the Federal Act on the Transparency of Legal Entities & Identification of Beneficial Owners (LETA). The revised AMLA broadens its scope to include “advisors” in certain cases.
This is not yet effective law until the implementing ordinances (AMLO) are finalised expected mid-2026 but the framework and legal basis are in place.
1. New legal category: Advisors (Berater)
Under the revised AMLA, the Act will explicitly apply to three categories:
- Financial intermediaries
- Dealers
- Advisors (new) — this is a new category added in the 2025 reform.
This is a legislative expansion beyond the traditional AMLA scope, which previously focused on financial intermediaries and dealers only. The official Federal Gazette (BBl) text includes the new category.
2. Who is an Advisor under the revised AMLA?
The AMLA now defines advisors as persons or entities that professionally participate in financial transactions or legal operations for third parties. The legislative text adopted by Parliament includes this new category.
Importantly:
- It is not simply any advisor;
- The advisory activity must be professional and related to financial/legal transactions with a risk of money laundering or terrorist financing.
Activities covered — as confirmed by practitioners analysing the law — include:
- Transactions involving non-operational legal entities, especially in corporate structuring and domiciliation services
- Certain real estate transactions
- Provision of domicile or registered office services
- Other structuring or transactional advisory activities with elevated AML risk
This means the law now captures some advisory roles that previously fell outside AMLA.
3. What duties advisors will have under AMLA
While the full final texts of the ordinance (AMLO) that implement the AMLA are still being drafted, the emerging duties for covered advisors include the following (as reflected in parliamentary intent and practice guides):
3.1 Due Diligence (“Sorgfaltspflichten”)
Advisors will be required to take risk-based due diligence measures in connection with covered transactions, including:
- Identifying the contracting party
- Identifying the beneficial owner
- Understanding the economic purpose of the transaction
- Documenting findings appropriately
These obligations are similar in nature to those already imposed on financial intermediaries, but tailored to advisory activities.
3.2 Organisational measures
Advisors will need to adopt proper internal controls and compliance systems, including:
- Written AML/CFT policies
- Procedures for client onboarding and risk assessment
- Documentation systems
These organisational requirements are consistent with AML compliance duties that have been mentioned in multiple legal analyses.
3.3 Suspicious activity reporting
Advisors will be subject to reporting obligations — they need to report suspicious transactions to the Money Laundering Reporting Office Switzerland (MROS) if they identify reasonable suspicion related to money laundering or terrorist financing.
This is a significant extension compared to prior law, where only financial intermediaries had clear reporting obligations.
3.4 Affiliation to an SRO
The revised AMLA maintains the model of requiring covered persons (including advisors once in scope) to either:
- Be supervised by FINMA directly, or
- Join a self-regulatory organisation (SRO) recognised by FINMA
This mirrors the approach used for financial intermediaries today.
Advisors will therefore need to affiliate with an SRO if their activities fall within the AMLA’s scope.
4. Exceptions & professional secrecy
The law as adopted attempts to balance AML duties with professional secrecy obligations particularly for lawyers, notaries, and other regulated professions.
According to legislative discussion and reporting, traditional activities such as representation in litigation and advice in judicial/criminal/administrative proceedings are excluded from the AMLA scope, even if undertaken by covered professionals.
However, advisory activities linked to financial/legal structuring (outside litigation context) will likely fall within the regime. This is an important nuance — the law is not a blanket capture of lawyers in all activities.
5. Effective date
The revised AMLA and related transparency law (LETA) were adopted in September 2025, but the actual duties on advisors will not be binding until the implementing ordinances (AMLO) are finalised and enter into force — expected mid-2026.