Switzerland’s 2025 regulatory overhaul marks a decisive shift in the fight against financial crime, demanding that financial institutions reassess and upgrade their data estates and control frameworks. The Financial Action Task Force’s Mutual Evaluation Report on Switzerland highlighted areas of focus (R.22, R.23, R35), namely due diligence controls, a focus on fighting professional enablers, and ensuring “effective and proportionate sanctions” for anti-money laundering (AML) and counter-financing of terrorism (CFT) violations.
The Swiss Parliament’s adoption of the revised Anti-Money Laundering Act (AMLA) and the implementation of the Federal Act on the Implementation of Recommendations of the Global Forum on Transparency and Exchange of Information for Tax Purposes has set a new standard for transparency, accountability, and operational resilience in the financial industry. Institutions now need to demonstrate not only compliance on paper but also the effectiveness of their controls in practice, as Swiss regulators, and international bodies—like the FATF and EU—enhance their review and enforcement of the implementation, effectiveness, and risk-based adequacy of AML/CFT measures across institutions.
Enforcement actions have resulted in fines totaling more than CHF 100 million imposed on Swiss financial institutions in 2025. The introduction of the central Ultimate Beneficial Ownership (UBO) register (Article 697j of the Swiss Code of Obligations and the new Article 2a AMLA) is impacting more than 600,000 legal entities in Switzerland, which significantly enhances corporate transparency by making beneficial ownership information more accessible, thereby strengthening cross-border cooperation in financial crime investigations.
Major banks have faced penalties for failures in AML screening, entity, beneficial ownership (BO) verification, and due diligence that lacks effective triggers. Delays in reporting suspicious activities to the Money Laundering Reporting Office Switzerland (MROS) further increase the risk of financial crime going undetected. The FIU.net European engagement provides a vision for enhanced data sharing in the region to help mitigate this risk.
Effective implementation, monitoring, and oversight are essential to AML/CFT compliance. Senior management and compliance officers may be held personally accountable for failures in AML/CFT compliance under Article 29 AMLA and governance obligations outlined in FINMA Circular 2017/1. Enforcement proceedings and, in some cases, criminal liability may be initiated for failures in internal controls.
The proliferation of digital assets, the global reach of sanctions regimes, and the increasing sophistication of financial crime all heighten risk exposure. At the same time, customers—both corporate and individual—expect robust protection of their assets, transparent risk management, and responsible use of data and artificial intelligence (AI). Meeting these expectations requires a proactive approach to data governance, privacy, and security, as well as the ability to adapt quickly to new threats and regulatory demands.
To meet these enhanced expectations and mitigate emerging risks, regulatory authorities and industry stakeholders have introduced a range of targeted compliance measures and operational standards. This is illustrated by a focus on Crypto exchanges and wallet providers who must verify wallet ownership, monitor transactions above CHF 10,000, and comply with the “travel rule” for originator and beneficiary information.
To address the evolving risk landscape, Swiss banks are implementing FINMA Guidance 08/2024 to strengthen AI governance. They are also aligning with Circulars 2018/3 and 2023/1, which focus on operational risks and data security—particularly in relation to cloud hosting and SaaS environments. In parallel, institutions are investing in modernizing their data estates and integrating AI into their compliance frameworks.
To address key challenges, financial institutions can consider focusing on areas influencing risk management and compliance, including:
By embracing these changes, Swiss financial institutions can prepare their compliance and control frameworks for success, while also building operational efficiency and trust with customers.
As Switzerland ushers in a new era of financial crime prevention, the integration of digital asset oversight into traditional compliance frameworks is no longer a future ambition — it is an imperative.
The strategic alliance between Moody’s and Elliptic offers Swiss financial institutions advanced, , data-driven tools to support their efforts in navigating this evolving regulation.
By uniting dynamic blockchain intelligence with trusted off-chain analytics, this alliance can help compliance teams modernize their control environments, support VASP due diligence, and mitigate enforcement risk.
For more information, please get in touch with the team—we would love to hear from you.