FINMA amends Anti-Money Laundering Ordinance and two self-regulatory rules, effective in 2027

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FINMA has published partial amendments to the Anti-Money Laundering Ordinance and recognized the Swiss Banking Due Diligence Agreement and the Swiss Insurance Association’s self-regulatory organization rules as minimum standards. All three rules will take effect on January 1, 2027. The two self-regulatory rules provide for a four-month transition period; the ordinance amendments clarify the scope of application to correspondent banking services provided by foreign banks and add requirements concerning ownership and control structures, sanctions monitoring, and recordkeeping. The revised Anti-Money Laundering Act covers certain advisory services, and FINMA has separately explained the scope of application of the relevant circular and responsibility for supervising advisory work.