Revised Anti-Money Laundering Act: advisers must apply to an SRO by 1 December 2026

The revised Swiss Anti-Money Laundering Act (AMLA) has been in force since 1 October 2026. It brings advisers on financial transactions, such as real estate deals and the formation or administration of non-operating legal entities, under the Act. Advisers who were already active on 1 October 2026 must file an application to join a self-regulatory organisation (SRO) by 1 December 2026.

The revised Anti-Money Laundering Act

The revised Swiss Anti-Money Laundering Act (AMLA, German GwG) has been in force since 1 October 2026. Parliament adopted it on 26 September 2025, and the Federal Council set the date on 12 June 2026. The due-diligence duties apply from 1 October 2026, with no grace period.

Who counts as an adviser

The AMLA brings a new group under the Act: advisers. These are natural and legal persons who, on a professional basis, assist third parties with financial transactions in connection with:

• the purchase and sale of real estate;
• the creation and formation of non-operating legal entities with a Swiss registered office, or of legal entities with a registered office abroad;
• the management and administration of non-operating legal entities;
• deposits into and distributions from non-operating legal entities;
• the purchase and sale of legal entities where a non-operating legal entity buys or sells.

Anyone who professionally provides an address or premises as domicile or registered office for legal entities for more than six months is also treated as an adviser.

Deadlines for existing and new advisers

Advisers who were already active on 1 October 2026 and are not yet supervised must file an application to join a self-regulatory organisation (SRO) by 1 December 2026. Until the SRO decides, they may continue only within existing business relationships. An adviser who does not apply in time, or is refused, may not continue to act as an adviser.

Financial intermediaries that are already supervised and also act as advisers must notify their SRO or supervisor of the advisory activity by 1 December 2026. No new admission is needed.

Someone who becomes an adviser after 1 October 2026, for example by crossing the professional threshold, must comply with the duties at once and apply to an SRO within two months.

Costs of SRO supervision

Typical cost at one large SRO (VQF), as published in June 2026, is shown below.

For details on supervision, see our article on what an SRO is and how it supervises. The VQF also publishes answers to common questions in its VQF FAQ.

Exceptions

The Act does not apply to lawyers and notaries for their work in court, criminal, administrative or arbitration proceedings.

How we can help

With the 1 December deadline less than four weeks away, Goldblum and Partners prepares SRO applications for fiduciaries, domicile providers and real estate advisers, and sets up the due-diligence file the SRO will review; see our SRO membership service.