New Anti-Money-Laundering Duties For Advisory Services In Switzerland

The revised Federal Anti-Money Laundering Act (AMLA) will become effective on 1 October 2026, concurrently with the newly introduced Federal Act on the Transparency of Legal Entities (see separate Bär & Karrer Legal Insight published on 15 June 2026). It subjects advisors providing certain transaction-related advisory services (e.g. lawyers, notaries, accountants, consultants, real estate agents etc.) to AML duties so far reserved to financial intermediaries. This change is important as transaction advice may now require AML controls at an early stage of a mandate.

Who is affected?

The new rules extend AML regulation to advisors acting in Switzerland or from Switzerland where their professional advice causally contributes to covered legal transactions linked to financial transactions.

Covered transactions focus on non-operating entities or real estate and include the following:

• Purchase and sale of real estate;
• Incorporation of non-operating entities with their legal seat in Switzerland or of entities with legal seat abroad;
• Management and administration of non-operating entities;
• Contributions and distributions of non-operating entities;
• Purchase and sale of legal entities where such transaction is exercised through a non-operating entity.

Real estate transactions are expressly covered once both parties have declared their intention to conclude the sale, unless an exemption applies.

Potentially, lawyers, notaries, real estate brokers, consultants, accountants and other advisors are subject to the new AML duties. However, it must be carefully analyzed on a case-by-case basis whether an advisor's specific activities are within the scope of the revised AML regulations.

When is advice professional?

Advisory activity is deemed rendered on a professional basis if it is independent, economically sustained and directed at permanent income. It is, in any event, professional where annual gross revenue from the advisory services exceeds CHF 50'000, more than 20 clients or relevant transactions are handled per calendar year or if the advice concerns assets which exceed CHF 5 million, or if the relevant financial transactions together exceed the value of CHF 2 million per calendar year.

What changes for advisors?

Advisors captured by the new rules must join a Self-Regulatory Organisation (SRO) which is supervised by FINMA. For membership and ongoing compliance, advisors must implement an AML framework including an appropriate onboarding concept (client identification and documentation of beneficial owner), appoint an AML/Compliance Officer and train their staff. Advisors who are not subject to the attorney-client privilege or notary-client privilege must also report suspicions to the Money Laundering Reporting Office Switzerland (MROS).

Moreover, advisors will obtain access to the new transparency register for AML due diligence purposes.

What changes for clients?

Clients should expect earlier and more granular requests for ownership, control chain and transaction information. Incomplete or inconsistent information may slow down mandate acceptance, transaction execution or access to certain services.

Timing and next steps

The new law enters into force on 1 October 2026. Advisors already carrying out covered activities on that date must submit an SRO application by 1 December 2026.

The practical priority is to identify affected services now, amend the client onboarding process, and inform clients what ownership and source of wealth information will be needed before receiving advice.

Conclusion

Implementing the new requirements will take time and requires substantial effort from advisors within the scope of the revised AMLA. We therefore recommend starting as soon as possible with the process and obtaining legal advice to the extent necessary.

We recommend that clients who regularly require transaction-related advice compile a comprehensive KYC file to facilitate the onboarding process.