Harmonization of Swiss anti-money laundering legislation with FATF standards

Reacting to the fourth country report by the Financial Action Task Force (FATF) on Switzerland in December 2016, the Swiss Federal Department of Finance (FDF) analyzed the published recommendations and weaknesses.

The Swiss Federal Council explained that in order to remedy identified weaknesses, the Anti-Money Laundering Ordinance of the Swiss Financial Market Supervisory Authority (AMLO-FINMA), the Agreement on the Code of Conduct with regard to the Exercise of Due Diligence (CDB) and the regulations of the Self-Regulatory Organizations must be adapted.

The hearing on the partial revision of the AMLO-FINMA was completed on 16 October 2017. The consultation process will open shortly. The revised ordinance is scheduled to enter into force in 2019.

The hearing for the AMLA is expected to start in Q2/2018.

The Swiss Bankers Association plans to amend its CDB 16 to reflect the revised AMLO-FINMA.

2019 2020 2021 2022 2023 2024
7 8
  • 3 Result of consultation 04/18-06/18
  • 5 Publication of final decree 07/18-12/18
  • 7 Enactment / transitional period 01/19-12/19
  • 8 Application of the rule of law 01/20-12/99


The AMLO-FINMA is not expected to come into force until 2019 at the earliest. In order to publish the amendments to CDB 16 in line with AMLO-FINMA, we assume that the new CDB will also come into force in 2019. It is conceivable that prior to revising the AMLO-FINMA, a revision of the AMLA legislation will be carried out in order to create the necessary basis for the AMLO-FINMA. This could impact the timing of the new AMLO-FINMA and CDB guidelines. The changes as a whole pertain specifically to the verification of beneficial owners and the regular updating of customer information. Financial intermediaries and retailers should familiarize themselves with these upcoming amendments in a timely fashion and adjust their internal directives, processes and IT systems and begin training their employees, if necessary. In doing so, it is recommended to use a holistic approach. Practice has shown that updating IT systems, reviewing client files (if necessary) and training employees are generally the most pressing issues, which is why they should be given priority.

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