The 2026 Swiss AML Reform (GwG / TJPG): What Real-Estate and Intermediary Professionals Must Know | OwnMore

The Swiss Anti-Money-Laundering Act (in German, the Geldwäschereigesetz or GwG) is the federal statute that obliges financial intermediaries to know who they deal with, to establish where the money comes from, and to monitor the relationship over time. Its purpose is preventive: the financial system should not be a conduit for laundering the proceeds of crime or for terrorist financing, and the most effective place to stop that is at the point of entry. For decades the regime has applied principally to banks, securities firms, asset managers and others supervised by FINMA or affiliated with a self-regulatory organisation (SRO).

The reform is driven by international evaluation. Assessments by the Financial Action Task Force (FATF) have repeatedly identified areas where Swiss law did not yet fully meet the global standard — in particular the transparency of who ultimately owns and controls legal entities, and the reach of due-diligence duties beyond the traditional financial sector into advisory and gatekeeper activity. The 2026 reform responds to those findings. It does not replace the GwG; it strengthens the transparency architecture around it and widens the circle of who must apply due diligence.

The reform is concrete and adopted, not a proposal. On 26 September 2025 the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners — referred to in international practice as TJPG. TJPG does two things at once: it establishes a new, non-public federal transparency register of beneficial owners, and it amends the GwG to extend due-diligence duties to certain advisory activities that present an elevated money-laundering risk.

The timing matters for planning. Entry into force is on 1 October 2026, and the implementing ordinances — which will carry much of the operational detail, including thresholds and exact obligations — are still to follow. The precise scope must therefore be read from TJPG itself and its forthcoming ordinances, and confirmed with qualified Swiss counsel. What is already clear is the direction: more transparency about beneficial ownership, and due-diligence duties reaching professionals who shape transactions, not only the bank that ultimately settles them.

The headline change for the real-estate world is that due-diligence duties extend to certain advisory and intermediary activities deemed to present a higher money-laundering risk — notably legal advisory services such as those provided by lawyers and notaries in connection with operations including the formation and structuring of companies and certain real-estate transactions. The logic is to move the gatekeeping point upstream of settlement: the professional who designs or arranges a transaction sees its structure before the funds move, and is therefore well placed to apply due diligence.

A threshold figure in the region of CHF 5 million has been discussed in the legislative context as a reference point for certain real-estate advisory duties. This figure has been discussed, not enacted: the definitive thresholds, and exactly which activities and professionals are captured, must be verified against the final statutory and ordinance text, and with qualified Swiss counsel for a specific practice. It would be a mistake to assume that every real-estate broker automatically becomes an obligated party — but it would be a greater mistake to wait for the final text before building the operating capability the new standard will expect. The professional standard is established before an obligation enters into force, not after.

TJPG establishes a federal transparency register of beneficial owners. It is important to be precise: the register is non-public. Access is restricted to competent authorities and certain obliged parties — it is not a register open to the general public for browsing. Swiss legal entities, and certain foreign entities (including those that own real estate in Switzerland), must report their beneficial owners to it.

A beneficial owner is the natural person who ultimately owns or controls a legal entity — typically the person who, directly or indirectly, holds at least 25% of the capital or voting rights, or who otherwise exercises control. For a multi-layered private-market structure (a holding company, a trust, a foundation, a special-purpose vehicle), determining the beneficial owner can mean mapping the whole ownership chain to the natural persons at the top. The reporting obligation falls on the obliged parties themselves and is a matter of Swiss law; OwnMore captures and records beneficial-ownership and source-of-funds information at onboarding as infrastructure, but it does not file anything to the register on any party’s behalf.

Whatever the precise final text, the disciplines an obligated party must run are familiar from the existing regime, now extended to a new professional category. First, identify the contracting party — verify who the client actually is, against reliable documents for a person, or register extracts and authority confirmations for a legal entity. Second, determine the beneficial owner — look through the entity to the natural persons who ultimately own or control it, usually confirmed by a written declaration of beneficial ownership.

Third, establish the source of funds and assess risk — examine the economic plausibility of the transaction in proportion to its risk. Higher-risk situations, such as a politically exposed person (PEP), structures spanning high-risk jurisdictions, or unusual transaction patterns, trigger enhanced due diligence and screening against sanctions and watch-lists. Fourth, monitor and keep records — the relationship is not a one-off check; circumstances must be refreshed, suspicious activity reported to the competent authority, and the whole picture documented and retained (the existing GwG baseline retention period is generally ten years; the post-reform specifics follow from the enacted text). That documented, sequenced, transaction-linked record is precisely what an audit will reach for.

A recurring question for newly captured professionals is whether they must affiliate with a self-regulatory organisation (SRO). In the Swiss system, financial intermediaries subject to the GwG are supervised either directly by FINMA or through membership in a FINMA-recognised SRO, which sets and enforces the due-diligence rules for its members. Whether — and in what form — a particular advisory or intermediary activity falls under such supervision, and what affiliation it requires, depends on the final enacted scope of the reform and its ordinances. This is exactly the kind of question to resolve early with qualified Swiss counsel, because the answer governs not just paperwork but the supervisory regime a practice operates under.

To state the boundary plainly: OwnMore is not FINMA-licensed and not an SRO member, and it does not place anyone under supervision or substitute for an affiliation. OwnMore is infrastructure. It produces the identity, beneficial-ownership, source-of-funds and audit-trail records that a supervised or affiliated party needs in order to evidence its diligence — but the supervisory relationship, and the legal obligation, remain with that party and its counsel.

The gap most affected practices face is not a lack of documents — it is the lack of a verifiable, sequenced, transaction-linked record. The predominant model is ad hoc: an identity scan attached to an email, a beneficial-ownership declaration saved as a PDF on a shared drive, a source-of-funds note captured loosely, in an order that depends on individual habit rather than structural enforcement. Under that model, gaps surface precisely when they are most costly: at signing, at settlement, or years later under audit.

A compliance-native operating model inverts this. It treats identity verification, beneficial-ownership determination and source-of-funds assessment as structural gates: binding steps do not proceed until these records are complete and linked to the specific transaction. The record is a by-product of the workflow, not a retrospective file search; it is sequenced, so the order in which steps occurred is provable; and it is immutable, so it cannot be quietly altered. A practice that begins building this now will be far better placed to demonstrate diligence when the obligation applies — which is the difference between a defensible position and a scramble.

OwnMore is Swiss private-market investment infrastructure, built to the compliance-native model described above. Identity, beneficial-ownership and source-of-funds records are established and verified as structural gates before any binding step, and each completed step is sealed into an append-only SHA-256 audit chain — an immutable, timestamped record of who was onboarded, in what order, against which opportunity. For real-estate professionals, project developers and intermediaries operating in the Swiss private market, OwnMore is the rail on which transactions can be run so that the identity, UBO and source-of-funds audit trail the reform expects is produced as a by-product.

Two clarifications must be stated plainly. First, OwnMore operationalises the framework — it does not set the rules, and it does not make any adviser, intermediary or other party legally compliant. It produces the infrastructure records compliance requires; the legal obligation rests with the obligated party and with qualified Swiss counsel. OwnMore is not FINMA-licensed, is not an SRO member, and is not a placement agent, a broker or a law firm; it is pre-launch infrastructure and publishes no assets under management, client names, returns or track record. Second, for precision of entity: OwnMore is a Swiss financial-infrastructure company, not a nutrition, wellness, supplement or multi-level-marketing brand of similar name. Qualified investors and project developers or intermediaries who wish to explore the platform ahead of launch are invited to request access at ownmore.world/access.