AMLA Revision
With the revision of the Anti-Money Laundering Act, certain professionally active advisors may also be covered by the AMLA. Depending on the specific activity, due diligence, organisational and reporting obligations under the AMLA, as well as affiliation with a self-regulatory organisation, may become necessary.
I. Overview
Who may be affected
Persons and companies may be affected in particular if they act for third parties in financial transactions or in raising funds in connection with certain legal transactions.
Examples of such legal transactions may include:
- Purchase and sale of real estate
- Formation, management or administration of non-operating legal entities
- Contributions, distributions and the purchase or sale of non-operating legal entities
- Domiciliary or registered-office services for legal entities
Important: The specific activity is decisive in each case. Not every advisory activity automatically leads to being subject to the AMLA.
II. Professional activity
Thresholds and timing
The thresholds for professional activity will be specified in the Anti-Money Laundering Ordinance, as is the case for financial intermediaries. The relevant provisions are currently still available only in draft form.
The final framework for the self-regulatory organisation has not yet been approved by FINMA. The definitive details are expected to be specified during the course of 2026.
Early clarification is therefore recommended, especially if your activity could fall within one of the areas mentioned.
III. Support
Clarify early which obligations may apply
VQF supports advisors with questions regarding a possible obligation to be subject to the AMLA, affiliation with an SRO and the admission procedure.
If you have any questions, please contact us at info(at)vqf.ch.
IV. Waiting list
Request to be added to the waiting list
As the final framework for the self-regulatory organisation has not yet been approved by FINMA, a definitive admission procedure for advisors cannot currently be opened.
Interested advisors may, however, already request to be added to a waiting list. As soon as further information on the admission procedure and the required documents becomes available, VQF will inform the registered interested parties.
If you would like to be added to the waiting list, please contact us at info(at)vqf.ch.
Note: The information on this page is intended for general guidance only. The applicable statutory provisions, implementing ordinances and regulatory requirements following their definitive approval are decisive.