CH v13.3.0

Switzerland (CH) · Module Detail

Switzerland: AML/CFT & Financial Crime

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[Sentinel.gi-fed payments-context position] Switzerland's AML/CFT framework rests on AMLA (GwG), FINMASA, the Swiss Criminal Code (Art. 305bis), and AMLO-FINMA, with MROS (in the Federal Office of Police) as FIU. Financial intermediaries — including payment service providers and the para-banking sector — must affiliate with an SRO or be directly FINMA-supervised. The FATF rates the regime technically robust (8 compliant / 29 largely-compliant / 3 partially-compliant after 2023 re-ratings on R.10 and R.40); next mutual evaluation expected 2027/2028. The Travel Rule applies to blockchain transfers (threshold CHF 1,000 per the revised AMLA / CHF 0 per earlier FINMA practice), and FINMA prohibits transfers to unregulated wallet providers. A September 2025 reform (LETA + revised AMLA) introduces a federal beneficial-ownership register and extends AML duties to advisors, expected in force H2 2026.

Open gap — wpm-int-3No sentinel-fed AML finding for CH was located this cycle.no under-indexing note recorded
Horizon · 2026-H2 (± six months)LETA + revised AMLA — federal beneficial-ownership register and extended AML dutiesAdopted · Tier 3 source
Standing sub-brief · as of 27 June 2026249 words · last cycle 2026-06-27

AML/CFT & Financial Crime

This module is sourced from the Sentinel feed; original illicit-finance analysis belongs to FIM, and the intelligence below is carried as payments context only. Per Sentinel, Swiss AML rests on two pillars — money laundering as a criminal offence under SCC Art. 305bis and the AMLA requiring financial intermediaries to report suspicions to MROS — with FINMA monitoring prudentially-supervised institutions and SROs/SOs supervising others. The FATF assesses the regime as technically robust (8 compliant, 29 largely-compliant, 3 partially-compliant after 2023 re-ratings on R.10 and R.40), moving to regular monitoring ahead of the 5th-round evaluation expected 2027/2028.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T2sentinel://thepaypers.com/payments/news/finma-releases-anti-money-laundering-rules-to-blockchain-providers
  2. T?FIM (sentinel.gi) per-JID baseline profile — Switzerland — Switzerland's AML/CFT regime rests on the Anti-Money Laundering Act (GwG), FINMA supervision, and MROS reporting. FATF rates it compliant/largely compliant on 37 of 40 recommendations, but beneficial ownership transparency remains unimplemented, gatekeeper (lawyer/notary) AML duties are limited, and Banking Act Article 47 secrecy provisions chill investigative disclosure.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap
  4. T2FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: national listing
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence
  6. T2FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: Office of the Attorney General of Switzerland — MBaer Merchant Bank AG
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: political-constraint