The Swiss Federal Council announced (click here) a consultation on new measures introduced to strengthen Swiss anti-money laundering and counter-financing of terrorism (AML/CFT) rules.
In September 2025, the Swiss government passed a new law aimed at increasing transparency around the beneficial owners of Swiss organisations (the Transparenz juristischer Personen und die Identifikation der wirtschaftlich berechtigten Personen or TJPG). The new law was passed along with changes to the Swiss Money Laundering Act (the Geldwäschereigesetz or QwG), together aimed at enhancing Switzerland’s AML/CFT measures by giving the authorities the ability to see into opaque legal entity structures which may be used for illicit purposes. Importantly, the new rules are not directed exclusively at the financial sector but apply to all Swiss legal entities (with few exceptions) and extend in some cases to certain categories of legal entities under foreign law that have a close connection to Switzerland. The Federal Council is now seeking feedback on the new measures before they enter into force.
Under the TJPG rules, in-scope legal entities must identify their beneficial owners and verify this information by applying appropriate due diligence. A beneficial owner is defined under the rules as a natural person who ultimately holds at least 25% of the capital or voting rights in a company or who controls the company in some other way. After identifying and verifying its beneficial owners, the legal entity must report the information obtained to a new transparency register maintained by the Federal Office of Justice (i.e. Bundesamt für Justiz or BJ). The non-public register will house the details of the beneficial owners of all legal entities subject to the TJPG. While non-public, in addition to the regulatory authorities, financial intermediaries/advisors will have tightly controlled access to the register (per Article 25 of the TJPG) to perform their due diligence obligations;
Under the rules, a body set up under the Federal Department of Finance (Eidgenössischen Finanzdepartement or EFD) will be tasked with performing risk-based inspections of the legal entities captured in the register. To this end, the Swiss authorities are expected to rely on reports from financial intermediaries or other regulatory authorities regarding discrepancies between their information and the information in the register. They are also expected to perform random checks and any violations will be dealt with either by the supervisory authority or, for more serious matters, cases may be referred to the competent authority for criminal proceedings. The Swiss Money Laundering Act has also been partially revised as part of this legislative initiative. The Swiss AML rules will be extended to include “advisors” – mostly targeting legal advisors who engage in services with a high degree of money laundering risk. The changes to the AML rules are not likely to be significant for energy and commodity traders.
The consultation was released with several attachments, all of which are available in the Swiss official languages (but not English). The consultation does not contain structured questions. The documents of most likely interest include:
- The 33-page regulatory text (click here – the document is in Swiss German) – while the title suggests that this is TJPG text, it also contains the amendments to other related rules including the Swiss Money Laundering Act.
- The 74-page explanatory report (click here – the document is in Swiss German) – the report provides a useful article by article summary of TJPG and changes to the associated rules.
The other attachments relate to administrative matters. The law is scheduled to come into force in the second half of 2026, provided that the IT systems required to maintain the register are ready by then. For those wishing to respond, the consultation will remain open until 30 January 2026.
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