AMLA revision 2026: which advisors are newly covered and what do they have to do?

Which activities are covered

Advisors are persons who, for third parties and on a professional basis, assist with financial transactions, including fundraising, in connection with the following legal transactions (Art. 2 para. 3bis AMLA):

• purchase and sale of real estate;
• formation and establishment of non-operational legal entities with registered office in Switzerland or of legal entities with registered office abroad;
• running and managing non-operational legal entities;
• contributions to and distributions from non-operational legal entities;
• purchase and sale of legal entities, where a non-operational legal entity buys or sells.

Also covered is anyone who professionally provides addresses or premises as a domicile or registered office for legal entities for more than six months (Art. 2 para. 3ter AMLA). Depending on the activity, this concerns fiduciaries, lawyers, notaries and real estate agents, among others.

When advice is professional

Advice is always considered professional if one of the following thresholds is exceeded per calendar year (Art. 12f AMLO): gross revenue of more than CHF 50,000, more than 20 clients or legal transactions, third-party assets of more than CHF 5 million concerned, or financial transactions of more than CHF 2 million.

Key exceptions

Art. 2 para. 4ter AMLA exempts low-risk transactions, including:

• transfers of real estate and legal entities below CHF 5 million where the purchase price is paid exclusively via banks or financial intermediaries subject to the Act;
• the purchase of owner-occupied residential property in Switzerland;
• acting as a governing body of operational legal entities, non-profit foundations and operational associations with registered office in Switzerland;
• pure notarisation without ancillary advisory activity.

Persons licensed or supervised by the Federal Audit Oversight Authority are also exempt for their audit activities (Art. 2 para. 4bis AMLA).

What advisors have to do

• SRO membership: advisors must join an SRO (Art. 14 AMLA). Anyone already active on 1 October 2026 must submit an application by 1 December 2026 and may, until the decision, continue only within existing business relationships (transitional provision of the AMLO).
• Due diligence: identify clients, establish the beneficial owner, identify the purpose and nature of the transaction, keep records and, in the case of high risks, clarify the background (Art. 8b AMLA). The SRO determines the scope (Art. 8c AMLA).
• Reporting obligation: report to the Money Laundering Reporting Office (MROS) in case of knowledge or well-founded suspicion (Art. 9 para. 1ter AMLA). Lawyers and notaries are only obliged to report under the conditions of Art. 9 para. 2 AMLA.
• Organisation and training: take organisational measures and, in particular, ensure adequate training of staff and carry out controls (Art. 8d AMLA).

Financial intermediaries that are already supervised and also act as advisors had to notify their supervisory body of this activity by 1 December 2026 (transitional provision of the AMLO, para. 2).

Check in 2 minutes whether you are affected

• Use the AMLA check to see whether one of your activities is covered.
• Assess whether your activity is professional using the thresholds in Art. 12f AMLO.
• Check the exceptions under Art. 2 paras. 4bis and 4ter AMLA.
• Choose an SRO and submit the application (deadline for existing activities: 1 December 2026).
• Set up internal directives and a KYC process.
• Train your staff and document the training.

Sources

• Anti-Money Laundering Act (AMLA), SR 955.0 – English translation (not legally binding)
• Anti-Money Laundering Ordinance (AMLO), SR 955.01, as of 1 October 2026 (German)
• FINMA: self-regulatory organisations (SROs)

This article provides an overview and does not constitute legal advice. The cited legislation and your SRO’s regulations are authoritative; legal provisions are paraphrased in English.