FINMA publishes partially revised FINMA Anti-Money Laundering Ordinance

For compliance teams, the practical effect is less about wholesale redesign and more about evidence: firms should test whether current onboarding, ongoing monitoring, beneficial-ownership and PEP controls align with the updated minimum standards and the newly issued guidance on Circular 2011/1. Financial intermediaries should also revisit whether their activities fall within the regulated perimeter, particularly where advisory, distribution or intermediary models have changed. Action items: map the revisions against existing AML policies and SRO obligations; update risk assessments and due-diligence checklists; refresh training and file documentation; confirm governance sign-off and audit trails.

Institutions with cross-border or intermediary-heavy models should prioritise legal-entity and licensing reviews. The revision reinforces supervisory expectations rather than creating an entirely new regime, so early gap analysis can reduce remediation risk and demonstrate proactive conduct. FINMA has not, in this announcement, set out detailed transition dates, so compliance leaders should track the ordinance’s effective date and any SRO implementation guidance before finalising changes.

Overall: moderate-to-significant operational impact for Swiss-regulated banks and wealth/advisory firms; limited direct impact for firms outside the Swiss perimeter.