Switzerland is entering a new phase in its anti-money laundering framework.
From 1 October 2026, the new Federal Act on the Transparency of Legal Entities and the revised Anti-Money Laundering Act will enter into force.
One of the most significant changes is the creation of a new federal Transparency Register containing information on the natural persons who ultimately control covered legal entities.
For startups and internationally structured businesses, this is more than an administrative filing exercise.
A cap table may show who legally owns the shares but it does not always tell the full story of who ultimately exercises control.
The new framework therefore makes beneficial ownership, voting rights, indirect control and corporate structures increasingly important compliance issues.
There is also another development that businesses should not overlook:
Switzerland is extending AML obligations to certain professional advisory activities involving elevated money-laundering risks, including specific activities connected with company formation and structuring and real-estate transactions.
This means that the impact is not limited to banks or financial institutions. Depending on their activities, legal professionals, corporate advisers and other service providers may also face new due-diligence obligations.
For startups, fintech and Web3 businesses, now is the right time to review:
• beneficial ownership and control structures
• shareholder and voting arrangements
• corporate and transaction documentation
• client onboarding and KYC processes
• whether professional advisory activities fall within the revised AML framework
Importantly, the rules do not apply identically to every business form or every advisory service. The analysis must be made according to the legal entity and the activity concerned.
At AryaTech Heidarpour, we are following the implementation of the new Swiss framework closely, particularly its implications for startups, fintech, Web3 businesses and cross-border corporate structures.
Official Federal Government information:
https://www.efd.admin.ch/en/newnsb/x3sKLxCJ6S3dQJtfvy0Tb?