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Swiss transparency register

Distinguish the transparency register from AMLA duties

The transparency register and customer due diligence serve different purposes. Register data can be a source, but it does not automatically replace an entity’s own checks.

Two frameworks, two perspectives

The transparency register concerns reporting and update duties for certain legal entities. The AMLA requires covered businesses to identify contracting parties and beneficial owners in relation to a business relationship or transaction and to document the assessment.

Establish beneficial ownership

For complex ownership and control structures, follow ownership, voting rights, contractual control and evidence through to the natural persons concerned.

Practical consequence

Keep register data, organisation charts, declarations and independent evidence distinct, resolve contradictions and record the decision in the AML file.

Sources