FINMA's Revised AML Ordinance (AMLO-FINMA) From 1 January 2027: What Swiss Financial Institutions Must Prepare

On 10 November 2026, FINMA published the final, partially revised FINMA Anti-Money Laundering Ordinance (AMLO-FINMA). It applies from 1 January 2027, the same day as the revised banks' due diligence code (VSB 27) and the revised SRO-SVV insurance regulations. This is a revision of the existing ordinance, not a new one, and FINMA says most of it writes existing supervisory practice into the text. The practical work is to make sure your files, sanctions controls and correspondent arrangements can show that practice on paper before the FATF on-site visit expected in May to July 2027.

What FINMA published on 10 November 2026

FINMA's press release states that the partially revised AMLO-FINMA is final, following a consultation that ran from 12 May to 9 June 2026. FINMA's Board also recognised VSB 27 and the revised SRO-SVV regulations as minimum standards. All three instruments take effect on 1 January 2027.

Two points from the release shape the planning:

• VSB 27 and the SRO-SVV regulations each carry a four-month transition period. The published amendment contains no separate transition provision for the ordinance itself, which enters into force on 1 January 2027. Plan on the ordinance applying in full from 1 January 2027.
• FINMA changed or clarified three things after the consultation. Art. 37 para. 5 now covers only clients with direct access to the correspondent bank's accounts. The explanatory notes now explain how ownership-and-control transparency relates to complex structures and domiciliary companies. They also explain how the monitoring provisions apply by analogy to Embargo Act measures.

The revision was timed for the FATF fifth-round evaluation. FINMA's explanatory report says the on-site visit is expected between May and July 2027 and that changes count only if they are in force by the end of it. That is why FINMA skipped pre-consultation and shortened the public consultation to about four weeks.

Which rule comes from where

Mixing up the layers is the most common drafting error in internal AML directives. The revision touches several, and they do not carry the same weight.

SECO enforces Embargo Act coercive measures. FINMA supervises the organisational rules that intermediaries must have in place.

What is new and what is existing practice

The table follows FINMA's published amending decree (provisional version dated 29 October 2026) and its final explanatory notes. Where the final text changes a point from the consultation draft, the table says so.

"Existing practice" does not mean "no work." FINMA examiners already expect these controls, but a firm that cannot show them in its files and directives will now be measured against a written rule.

Ownership and control structure (Art. 9b)

Art. 9b requires an intermediary to be able to understand the ownership and control structure of its contracting party. It sits beside Art. 9a on domiciliary companies and the existing rules on complex structures. FINMA's explanatory notes now say how these fit together and describe the risk-based approach and the documentation expected.

Two things follow in practice. The file should show the chain, not only the end point: who owns, who controls, and through which entities. And the depth of work should scale with risk, but the reasoning should be written down.

This is a customer due diligence duty on the intermediary. It is separate from the legal entity's own filing duty under the Swiss transparency register, which ComplyFactor covers in its Swiss Transparency Register guide.

Sanctions: Embargo Act measures (Art. 30)

The revised AMLA requires intermediaries to take organisational measures against breaches of Embargo Act coercive measures. Art. 30 AMLO-FINMA puts that duty into the ordinance and applies existing AML provisions by analogy. The final text applies Arts. 10, 20, 23 and 24, Art. 25 para. 1 let. a to c and paras. 2 and 3, Art. 26 para. 1 and Arts. 27 to 29 by analogy.

FINMA's explanatory report gives the expected content, taken from the Federal Council's dispatch: a risk analysis at regular intervals, internal directives, and, depending on size and activity, IT-supported screening of customers, counterparties and beneficiaries. FINMA states that Art. 30 adds no new duty. The consequence is that a firm which already treats sanctions as part of its risk analysis has a documentation task, while a firm that does not has a gap that FINMA has now written down.

Art. 30 creates no new reporting channel. Enforcement of the measures stays with SECO.

Correspondent banking and sub-accounts (Arts. 37 and 65)

Art. 37 para. 3 no longer says the check of a respondent's AML controls depends on the circumstances. New Art. 37 para. 5 deals with payable-through arrangements, where a foreign bank's clients can use a correspondent account directly. For clients of the respondent who have direct access to accounts of the correspondent bank, the intermediary may execute payments only if it ensures that the respondent has fulfilled its due diligence obligations and the respondent supplies the relevant documents on request. After the consultation, FINMA limited the rule to these direct-access clients.

Art. 65 para. 2 let. d requires a declaration from the contracting party on the beneficial owner whenever the contracting party keeps sub-accounts for individual customers. The text does not specify a separate declaration for each sub-account holder. Firms offering omnibus or sub-account structures should check that their account-opening forms always collect the contracting party's beneficial-owner declaration in that situation.

What it means by institution type

FINMA's explanatory report does not map the changes onto every intermediary category. If your institution type is not in this table, confirm the applicable provisions with the ordinance text or your supervisor or SRO before relying on this summary.

FINMA's release also says that the AMLA now reaches certain advisory services, so Circular 2011/1 on acting as a financial intermediary will be revised. In the meantime, Guidance 06/2026 sets out the circular's scope and supervisory responsibility. Press reports of the guidance say FINMA supervises advisory work carried out by institutions it already supervises, such as banks, while independent advisory work that involves no financial intermediation is not directly supervised by FINMA. Confirm this against the guidance itself.

Key dates

Implementation and gap-analysis checklist

Work through this in order. The first four items can start before the formal texts are fully digested.

1. Map your instruments. List which of AMLO-FINMA, VSB 27 or the SRO-SVV regulations govern your firm, and note the transition that applies to each.
2. Re-baseline the AML directive. Update cross-references to VSB 27 or the SRO-SVV rules and the renumbered chapters of AMLO-FINMA.
3. Add a sanctions chapter. Cover risk analysis, directives, screening scope, escalation and the split between your firm and SECO. Document why your screening approach (manual or IT-supported) fits your size and activity.
4. Sample ten to twenty client files for Art. 9b. For each, check whether the file shows owners, controllers and intermediate entities, and the reasoning for the depth of work. Record the gaps by client type.
5. Check onboarding forms for Art. 65. Confirm that your forms always collect the contracting party's beneficial-owner declaration where it keeps sub-accounts for individual customers.
6. Review correspondent and payable-through arrangements. Identify respondents whose clients have direct account access. Confirm how you ensure the respondent has met its due diligence obligations, obtain an undertaking to supply the relevant documents on request, and test that both work.
7. Fix payment data handling for Liechtenstein so these transfers are treated as cross-border.
8. Decide the adviser question. If any part of your business provides advisory services, confirm the AMLA perimeter and your SRO affiliation route.
9. Train and evidence. Brief the front office and compliance on the changes, and keep a record that you did.
10. Run an independent check before the FATF visit window. An independent AML review of the updated framework gives you evidence for an examiner or SRO.

ComplyFactor's AML Gap Analysis for Switzerland can test items 1 to 7 against your actual files, and its AML Regulatory Advisory service can help you work out what the revision means for your business model.

Illustrative examples

These are hypothetical, to show how the provisions work. They are not findings about any real firm.

A portfolio manager with corporate clients. A client file records a Luxembourg holding company and its 30% shareholder, but not the two intermediate entities between them. Under Art. 9b the firm should be able to trace the chain and explain why it stops where it does. The fix is a structure chart in the file and a note on the risk reasoning.

A bank with a foreign respondent. The respondent lets some of its clients instruct payments through the correspondent account directly. The bank has no way to confirm that the respondent has met its due diligence obligations for those clients, and its agreement says nothing about supplying the relevant documents on request. Under Art. 37 para. 5 the bank should be able to ensure the first and obtain the second before executing such payments.

A fiduciary firm with a pooled account. The firm's contracting party keeps sub-accounts for individual customers, but the file holds no declaration from that party on the beneficial owner. Art. 65 para. 2 let. d makes that declaration mandatory.

Frequently asked questions

Does the ordinance have a transition period?

The published amending decree has no separate transition provision and enters into force on 1 January 2027. VSB 27 and the SRO-SVV regulations each have their own four-month transition period, set out in FINMA's release. Treat 1 January 2027 as the date the ordinance applies.

Which source should we cite in our directive?

Cite the final FINMA instrument, not law-firm summaries. Most commentary published before 10 November describes the consultation draft, and article numbers or wording may differ from the final text.

Does Art. 30 make FINMA the sanctions enforcer?

No. SECO enforces Embargo Act measures. Art. 30 sets the organisational standard that FINMA supervises.

Does this change the video and online identification rules?

No. That is a separate revision of Circular 2016/7, which took effect on 1 November 2026. See FINMA video and online identification rules 2026.

Do advisers fall under AMLO-FINMA?

Advisers' obligations come mainly from the revised AMLA and AMLO and their SRO route. FINMA's release addresses advisers through Guidance 06/2026 and the planned revision of Circular 2011/1.

Where can I find the official text, and is it final?

FINMA publishes the amending decree and its explanatory notes on its 10 November 2026 press release page. The amending decree is labelled a provisional version. The definitive text will be published on Fedlex, the Swiss federal legal database, and that version governs. The published files are in German and French. Check Fedlex before you finalise your directive.

Sources

• FINMA, FINMA publishes partially revised FINMA Anti-Money Laundering Ordinance, 10 November 2026
• FINMA, Consultation on the partial revision of the AMLO-FINMA, 12 May 2026, with draft amending ordinance, explanatory report and key points
• Swiss Federal Council, Federal Council brings new anti-money laundering rules into force, 12 June 2026
• VQF, AMLA revision: advisors

This article is general information, not legal advice. Check the final FINMA texts and your supervisor's or SRO's guidance before changing your framework.