Swiss AML knowledge
Swiss AML obligations for fiduciaries: activities covered from 2026
Fiduciaries are not subject to the Swiss AMLA merely because of their professional title. What matters is the service actually provided to third parties, the role in a covered legal transaction and whether the activity is carried out professionally.
Key points
- Bookkeeping for an operating business does not automatically trigger AMLA applicability.
- Formation, management or administration of non-operating entities, contributions, distributions and longer-term domiciliation mandates may be relevant.
- Classical financial intermediation and the new advisory categories require separate analysis.
Which fiduciary services require review?
The real mandate workflow is decisive. Does the firm only prepare accounts, or does it also assume corporate functions, coordinate payments, form entities, administer a domiciliary company or implement distributions? Several administrative tasks may together amount to relevant participation.
Existing mandates should also be inventoried. For domiciliary companies, holding and asset structures, document which functions are assumed and who decides on movements of assets.
Professional activity and separation of services
The new advisory categories use thresholds including more than CHF 50,000 in gross revenue, more than 20 clients or legal transactions, over CHF 5 million in relevant third-party assets or more than CHF 2 million in transaction volume. One met criterion may be sufficient.
Revenue from general accounting should not be mixed indiscriminately with potentially covered services. A traceable allocation of services, mandates and revenue reduces the risk of an incorrect conclusion.
What AMLA applicability means in practice
If the Swiss AMLA applies, a one-off check is not enough. Depending on the activity, the business must identify the contracting party and beneficial owners, document its risk assessment, carry out enhanced enquiries for higher-risk cases and maintain a complete, up-to-date AML file. Responsibilities, approvals, training and periodic controls must also be organised in a traceable manner.
Practical checklist
- Map the service catalogue and actual process steps.
- Analyse domiciliation, corporate, formation and payment functions separately.
- Document thresholds using mandate and revenue data.
- Record the conclusion, exemptions and next review date.
Frequently asked questions
Are all fiduciaries subject to the AMLA from October 2026?
No. The specific activity, role, professional nature and possible exemptions are decisive.
Is bookkeeping itself covered?
Bookkeeping is not covered merely by its label. Additional structuring, management, corporate or payment functions may change the assessment.
Official sources
- Amendment to the Anti-Money Laundering Act (official German text)
- Implementing and transitional provisions (official German text)
- Anti-Money Laundering Act on Fedlex (official German text)
Related articles
- Swiss AML obligations for domiciliation providers and registered offices
- Maintaining a Swiss AML file: documents, checks and ongoing updates
This article provides general guidance based on the legal position as at 26 August 2026. It does not replace legal or professional advice on an individual case.
Assess AMLA applicability first
The free AML obligation check provides an initial non-binding indication. GwG-Plattform.ch then supports the structured organisation of contracting parties, files, checks and deadlines.