Beware the new Swiss AML Regulations: General overview for 2025

Switzerland has traditionally been one of the major fiscal centers for multinational capital movements, attracting businesses and people from all over the world. It provided a ground for global activities to be carried out due to the element of secrecy and a sound banking system in place.

Over recent years, the watch on money transfer and possession of firms has been championed by multinational firms like the FATF. Their response has always been to beef up new supervisory-skill measures.

These new measures, enforceable in 2025, stress over assessment and reporting obligations, together with harsh penalties for any breach. The developing framework tries to strike a balance between what one attractive place to do business is and up to which level in terms of integrity and clarity it obliges to meet global stakeholders’ expectations.

Recent enforcement actions give a strong signal of willingness on the part of the authorities to impose significant sanctions where they believe there have been inadequate efforts to meet one’s obligations, so no complaint naturally came.

It also regulates VASPs operating in cryptocurrencies and precious metals, each offering a structure for national and multinational firms. The regulated VASPs will have to execute enhanced scrutiny and reporting mechanisms to meet the new legal obligations. Buyers of turnkey platforms, encompassing Swiss-licensed VASPs with multi-asset trading platforms for sale, must consider such laws and enforcement practices.

Key Changes and Developments

The year 2025 did witness some powerhouse reforms in the regulatory space. However, among these reforms, one of the most significant was the requirement of a detailed 360-degree disclosure of UBOs for organizations, trusts, and other legal structures. This, in turn, has made it very difficult for people to hide themselves behind complex layers of ownership chains. Now it was mandatory for corporations to declare all their structures, and the burden of proving it extends even to subsidiaries and related entities. Digital asset platforms, including exchanges and wallet providers, were clearly put under a supervisory framework. Not only will transactions above CHF1,000 be subject to enhanced monitoring, but any suspicious activities on those transactions will immediately be reported to the pertinent authorities. The extended CDD procedures are related to high-risk clients, namely PEPs, those from high-risk countries, and complex, multi-layered ownership-structured entities. Verification is not an event; it is a process that should be sustained throughout the customer life cycle. Fines and feasible criminal liability have also been raised. Large entities have been made an example out of, and they showed an intent to slap penalties and sanctions with a very heavy hand. The new regulations also introduce mechanisms to reinforce cross-border cooperation. The new bilateral treaty with Panama, signed in 2024, sends a message for better electronic transmission of information, which could help to enhance investigations quickly and effectively. Domestic initiatives involve proposals for a clarity register and more rigorous standards of identification for beneficial owners.

Implications for Financial Institutions

It is vital for all local entities to put in place an effective internal mechanism to raise the standards. Such measures include the use of AI-enabled monitoring tools to observe transactions in real-time, legislation making it compulsory to inform about any suspicious activity, and record keeping of client identification and transactions for not less than ten years. This requires organizations to appoint in-house compliance officers in order to ensure that the regulations are adhered to, such as through regular internal audits on controls’ efficiency and employee training programs on emerging risks and procedural updates.

It is therefore necessary to exercise enhanced assessment in respect of high-risk customers. Firms need to understand complex ownership structures, constantly update information on the beneficial owner changes, and tighten transaction monitoring in high-risk jurisdictions and politically exposed persons. Failure in process will lead to heavy penalties, damage to reputation, or worse still, withdrawal of operational licenses. In that context, what it necessitates for complete compliance are digital asset surveillance, comprehensive transaction monitoring, and cross-functional coordination.

Oversight Bodies

Many authorities are involved in the implementation of the abidance structure. The key supervising institution is that of all supervised entities; its role is to audit and come up with prescriptions in cases where identified weaknesses are noted, and withdrawals of licenses for serious infringements.

This body also cooperates at the international level with other regulators, to safeguard cross-border abidance risks. The fiscal intelligence unit compiles and processes reports of suspicious transactions, looking for patterns indicating potential illegal business operations. This generally results in close coordination with public prosecutions for further investigations. Prosecutorial authorities conduct criminal investigations and are in a position to press charges against both natural and legal persons; they can also order sequestration of property linked to illicit business operations. Court procedures are carried out at the cantonal and federal levels; fines are given, custodial sentences and other kinds of penalties from the penal law are pronounced. Multi-layer supervision at all levels guarantees comprehensive monitoring from the very first report up to its final adjudication.

Enforcement Examples

There have been some recent incidents, and it appears this framework is functioning as intended. In February 2025, FINMA fined one of the major U.S. banks CHF 1 million. This came after their acceptance of illicit transfers, which were linked to Greece by a client advisor found to have presented bribes. Despite the controlling systems put into operation, the internal supervision failed to avert them. On the other hand, there was a fine applied to a European wealth management company having some kind of limitation after it permitted high-risk beneficial owners to act for several months but undetected in view of inadequate vetting that should have shown them as ultimate owners. In these few cases, authorities demonstrated their readiness to apply stringent penalties regardless of the size or reputation of the entity in question.

Outlook

Regulatory bodies imply that enforcement will be further tightened. This can include the operational start of a comprehensive transparency register, tightening of reporting demands, and increased use of technology to monitor abidance. Multinational collaboration in the deeper, quicker exchange of information in channels and standards for assessment will ease the way. It is, therefore, anticipated that entities shall be investing in technological systems, human resource development, and compliance infrastructure as part of mitigating these risks and aligning with the evolving demands.