Switzerland has tightened its anti-money laundering regime, and the change reaches well beyond Swiss banks. Revisions to the country's anti-money laundering legislation took effect on 1 January 2025, with a transitional compliance window closing on 30 June 2025. International companies that hold a Swiss AG (public limited company) or GmbH (limited liability company), bank in Switzerland, or route payments through Swiss correspondent banking channels must reassess their compliance position now.
Switzerland's updated anti-money laundering rules expand beneficial owner transparency, tighten know-your-customer (KYC) obligations, and widen the set of businesses treated as obliged entities. Affected companies must complete remediation of existing customer and ownership records by 30 June 2025. Those that miss the deadline risk administrative measures, friction in bank account opening, and restrictions on credit facility access.
This alert sets out what changed and when, which businesses are affected and on what thresholds, and the immediate steps international companies should take before the deadline.
What changed and when it took effect
Switzerland's framework rests on its anti-money laundering legislation (the Anti-Money Laundering Act) and is supervised by FINMA, the Swiss Financial Market Supervisory Authority. The 2025 revisions align the regime more closely with international standards and close gaps that had allowed some ownership structures to stay outside the reporting perimeter.
Three changes stand out. First, beneficial owner transparency has been strengthened. A new layer of ownership record-keeping obligations applies, and more indirect owners and persons exercising effective control now fall within scope. Structures recorded only in the Handelsregister (Swiss Commercial Register), searchable through the federal Zefix platform, may no longer be sufficient on their own.
Second, KYC requirements reach a wider range of transactions and advisers. Obligations that were concentrated on banks now extend further into designated non-financial businesses and professions, including certain advisers who help form companies or structure asset transfers.
Third, duties around ongoing monitoring and documentation have been raised. Obliged entities are expected to keep customer and beneficial owner files current rather than verified only at onboarding. Rights and duties of Swiss companies here interact with the Obligationenrecht (Swiss Code of Obligations), which governs corporate record-keeping.
The amendments took effect on 1 January 2025. Existing obliged entities have until 30 June 2025 to remediate files and update internal policies; businesses brought into scope for the first time must reach full compliance by the same date.
Who is affected and the threshold criteria
The following categories are directly affected.
- Banks and payment institutions conducting correspondent banking operations in or through Switzerland
- Asset managers, securities firms, and fund service providers active in Swiss capital markets
- Non-bank lenders offering credit facility products to Swiss-connected borrowers
- Trust and company service providers forming or administering a Swiss AG or GmbH
- Advisers and intermediaries facilitating asset transfers above the revised thresholds
For international companies, risk concentrates in two places. First, any foreign group holding a Swiss subsidiary is an indirect obliged entity through that subsidiary's banking relationships. Swiss banks will request fuller beneficial owner information at bank account opening and on a recurring basis, and gaps will stall account maintenance and new credit facility applications.
Second, groups using Switzerland as a treasury or holding hub must confirm that their Swiss counterparties have completed their own remediation. Correspondent banking lines are under closer scrutiny, and a Swiss bank may restrict a relationship where the foreign counterpart's anti-money laundering programme does not meet the updated standard.
For the underlying obligations, see the firm's advisory on banking and finance law in Switzerland.
To review how the updated rules affect your Swiss banking and treasury arrangements, contact us at info@ferrazwhitmore.com for a preliminary compliance review.
Immediate actions before the 30 June 2025 deadline
International companies should treat the following as a priority checklist.
1. Audit beneficial owner records. Confirm that every Swiss entity in the group has accurate, current beneficial owner information and that the new record-keeping layer is in place. Indirect owners previously below the threshold may now require registration; missing entries expose the entity to administrative measures and banking friction.
2. Refresh KYC files held by Swiss banks. Contact the relationship managers at each Swiss bank where the group holds accounts and confirm the documentation now required. Bank account opening and maintenance will increasingly require certified beneficial owner declarations, source-of-funds evidence, and current group-structure charts.
3. Review correspondent banking arrangements. If the group relies on Swiss correspondent banking channels, obtain confirmation that each Swiss bank has updated its own programme, since a deficient counterpart carries operational and reputational risk for the foreign side.
4. Assess credit facility exposure. Swiss lenders now apply enhanced due diligence where a borrower's ownership structure falls short of the updated disclosure standard. Companies drawing on or renewing a credit facility after 30 June 2025 without compliant documentation risk delay or refusal.
5. Update internal policies for Swiss operations. Any compliance manual that references Swiss thresholds should reflect the 2025 revisions, especially where home-country obligations extend group-wide and a subsidiary gap would surface in a group audit.
Companies active in Swiss securities and fund work should also review our overview of capital markets law in Switzerland.
For companies tracking parallel developments elsewhere in Europe, the related AML update in Portugal covers comparable obligations in another EU-adjacent market.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking and finance regulation, anti-money laundering compliance, and corporate transparency. We advise international companies maintaining a Swiss AG or GmbH, opening and operating Swiss bank accounts, and managing correspondent banking and credit facility arrangements under the updated rules. Engaging a lawyer in Switzerland with cross-border compliance experience is particularly valuable when group-wide policies must be reconciled with local change. As an international law firm covering Switzerland and the wider European market, Ferraz & Whitmore helps clients meet the 30 June 2025 deadline with practical, results-oriented counsel. To discuss your compliance position, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.