Switzerland – FINMA AML Beneficial Owner

On 4 September, FINMA proposed new AML rules, for beneficial ownership.

  • Follows fourth round mutual evaluation of Switzerland's AML provisions by FATF.
  • Due to shortcomings, country entered the FATF enhanced follow-up procedure.
  • Amendments are part of wider package of measures in response to FATF report.
  • Package was summarized in a 28 June 2017, release issued by Federal Council.
  • Amendments include follow-up measures formulated in response to evaluation.

Beneficial Ownership

  • Proposals included rules on verification of information for beneficial ownership.
  • Financial intermediaries have duty to verify beneficial information on all clients.
  • Including for low risk clients, and firms must regularly updates the information.
  • Proposed flexible implementation, on verification methods used by Swiss firms.
  • Specified the obligations for intermediaries having foreign branch or subsidiary.
  • FINMA lowered cash thresholds for verification, from CHF 25,000 to CHF15,000.


  • Comments are due by 16 October 2017.