New SRO FAQ on advisory activities under the Swiss AMLA

Since 1 October 2026, the revised Swiss Anti-Money Laundering Act (AMLA) also applies to certain professional advisory activities. A joint FAQ by seven self-regulatory organisations (SROs), prepared in coordination with the State Secretariat for International Finance (SIF), answers 33 practical questions. It offers guidance on interpretation; the Act, ordinances and requirements of the competent supervisory body remain authoritative.

Key points

• The FAQ reflects guidance from the participating SROs; it is not a binding decision on an individual case.
• Registered-office and co-working services depend on actual use and additional services.
• For property mandates, the specific contribution to the transaction matters.

When is a holding company considered operational?

The FAQ follows existing practice under the AMLA and the FINMA Anti-Money Laundering Ordinance. A holding company may be considered operational if it directly or indirectly holds majority interests in operational companies, groups them under unified management, and actually exercises its management and control powers. Its main purpose must not be the management of third-party assets. The facts matter; the name or legal form alone is not decisive.

Registered offices and co-working depend on actual use

Under the FAQ, simply renting premises is not covered where the company carries out effective activity there. Employees, a secretariat or other signs of business activity at the location may support that assessment. If there is no effective activity, providing premises or an address may fall within the AMLA. Mail handling or forwarding and several companies registered at the same address are listed as possible indicators.

The FAQ distinguishes between co-working arrangements. A temporary workplace under a contract of no more than six months is not covered under this interpretation. A specified workplace from which the company effectively operates is also treated differently from a desk allocated according to availability together with a c/o address and additional services. The latter arrangement may be covered.

Property brokerage: the actual contribution matters

Simply publishing property listings is not covered under the FAQ. The relevant question is whether the activity is sufficiently connected to a specific property transaction and causally contributes to a sale or purchase contract being concluded. Additional brokerage or support services therefore need to be assessed in context.

Practical checklist

Businesses should record their actual services and workflows, distinguish activities involving operational and non-operational legal entities, and document how premises or co-working services are used and which additional services are provided. For property mandates, the role played in the specific transaction should be clear.

The FAQ also addresses statutory exemptions, professional-activity thresholds and transitional questions about SRO membership. These points should be checked against the circumstances of each business and current guidance from its SRO. Read more about new AMLA obligations for advisers and SRO membership deadlines in 2026.

Official sources

• PolyReg SRO FAQ on advisory activities
• Revised Swiss AMLA on Fedlex

This article provides general information and is not legal advice. Applicable law and the competent supervisory body govern individual cases.

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