The 2026 Swiss AML Reform for Property Developers and General Contractors: What Changes | OwnMore

Real-estate projects concentrate large asset values, often over short timespans and across multiple parties: buyers, co-investors, equity contributors, lenders and project entities. That constellation — high transaction values, structured ownership and the inflow of funds from different sources — is exactly what anti-money-laundering regimes systematically address. Where substantial amounts change hands and beneficial ownership is layered, the risk that the AML framework is designed to prevent is most acute.

Whether a developer or general contractor is directly captured as a financial intermediary under the GwG depends on the specific business model and the enacted scope of the legislation. What matters in practice is that even parties not classified as financial intermediaries are embedded in transaction chains where regulated counterparties — banks, payment-service providers, licensed platforms — must themselves fulfil due-diligence obligations. A developer or contractor who cannot document who is providing funds and who beneficially owns the counterparty becomes the bottleneck in the process.

The GwG reform expands this perimeter. LETA — the federal act on transparency of legal entities and identification of beneficial owners — was adopted by parliament on 26.09.2025. Entry into force is expected in H2 2026; no specific date has been fixed and the implementing ordinances are still to follow. Whether and how developers and general contractors are directly captured depends on the enacted scope and qualified legal counsel. This article is educational and does not replace advice.

The centrepiece of LETA is a non-public transparency register into which Swiss legal entities must enter their beneficial owners (UBOs). The register is not publicly accessible but is available to authorities and financial intermediaries — a deliberate departure from the publicly accessible model of the EU AML directive. For developers and general contractors operating as a GmbH or AG, this means: the UBOs of their own entity must be registered before regulated counterparties can engage without friction.

LETA also extends due-diligence obligations: the threshold at which a business relationship must be subjected to closer examination is lowered, and documentation duties for beneficial ownership and source of funds are sharpened. Financial intermediaries — including banks and platforms through which a construction project is financed or processed — will impose stricter requirements on the quality and currency of UBO information.

During parliamentary debate on LETA, a transaction-linked threshold of CHF 5 million was discussed, above which heightened due-diligence obligations for real-estate transactions would apply. That threshold was discussed but was not enacted in that form. What governs is exclusively the enacted legislative text and the implementing ordinances still to follow. Anyone seeking to determine specific thresholds applicable to their business model must consult the primary sources and qualified legal counsel.

Construction projects are frequently held in special-purpose vehicles (SPVs) — a GmbH or AG that carries a single project. This structure has sound tax and liability rationale, but it creates a UBO dimension that the reform explicitly addresses. The natural persons behind the developer SPV must both be entered in the transparency register and be declared to regulated counterparties. Anyone operating multiple project entities must maintain UBO compliance for each entity separately.

On the buyer side the same logic runs in reverse: purchase agreements for multi-family properties, commercial real estate or project participations are frequently signed not by natural persons but by companies. Where the buyer is a legal entity, its beneficial ownership — who stands behind the purchasing GmbH or AG — must be established and documented by the regulated participant in the transaction. For the developer this means: buyer onboarding is not a mere formality but a structured step with a documented record.

Co-investors and equity partners in a construction project are subject to the same scrutiny: where do the funds originate? Who is the beneficial owner? In elevated-risk situations — politically exposed persons, offshore structures, jurisdictions with heightened money-laundering exposure — enhanced due diligence applies. In all these cases the principle holds: the earlier the documentation is assembled, the lower the friction at every subsequent procedural step.

AML due-diligence obligations are not a one-time event but accompany a transaction from first contact through to title transfer. At counterparty onboarding — the earliest stage — the identity, beneficial ownership and source of funds of the buyer or investor are established. This is the most cost-effective stage for rigorous documentation: once contracts are signed and funds are flowing, retroactive correction is expensive and risky.

At payment events — purchase-price instalments, equity contributions, draw-downs on financing — documentation obligations become acute. Banks and payment-service providers verify that the relevant parties are correctly identified and that source of funds is plausibly documented. A buyer or co-investor whose UBO documentation is incomplete can block payment flows — in the worst case during time-critical construction progress.

At handover and title transfer the circle closes: the notary, land register and any financing bank expect clean documentation. Records must typically be retained for several years under the Swiss GwG regime. Anyone managing project transactions in isolated files without a unified evidence trail risks being unable to produce complete records in full when a subsequent inquiry arises.

The record-keeping obligation is not limited to individual documents. It encompasses the traceable sequence of due-diligence steps: when each check was performed, what information was available, what decisions were taken on what basis. A timestamped, immutable evidence trail per project is what an audit or regulatory inquiry expects.

In practice many construction projects look like this: KYC documents in email attachments, purchase-contract scans in a local drive, UBO declarations in a PDF folder, payment confirmations with the accounts team. That scatter is not an individual failing — it is the natural result of transactions where dozens of parties produce documents over months. The problem surfaces only when an auditor or authority requests a coherent record of due-diligence compliance for a specific project.

The value of an operating layer lies not in creating new obligations but in structuring the existing ones so that evidence is produced as a by-product. A system that writes identity verification, UBO declaration, source-of-funds evidence and payment event into a chronological, immutable chain resolves the evidence problem structurally. Not because it takes over the due-diligence step, but because it ensures that the step is documented with a timestamp and is traceable.

For developers and general contractors running multiple projects in parallel, this need multiplies. Each project entity, each buyer, each co-investor is a separate evidence case. A scalable solution is one where the same documentation structure applies to every transaction — regardless of project volume or number of parties.

OwnMore is compliance-native infrastructure for Swiss private-market real-estate transactions. That means: identity verification, UBO determination, source-of-funds evidence and qualified-investor gate are structural gates — not optional steps. Each sequence is sealed into an append-only SHA-256 audit chain, so the record of the proper order is held alongside the transaction record. OwnMore is built for the standard of the Swiss GwG regime — not in response to external scrutiny, but as the operational foundation.

Three clarifications, plainly stated. First: OwnMore is not a FINMA-licensed intermediary, not an SRO member, and not a law firm. SRO affiliation, FINMA-supervised custody and integrated AML screening are in preparation (pre-launch). OwnMore makes no one legally compliant — it provides the operating layer that structurally enforces and documents correct procedure. Anyone assessing their own legal obligations must consult qualified Swiss legal counsel and the primary sources.

Second: OwnMore publishes no assets under management, client names, returns or track record. Those figures are absent because OwnMore is pre-launch infrastructure — not because they are being withheld. Third, this article is educational. LETA was adopted on 26.09.2025; entry into force is expected H2 2026, no specific date is fixed, and the implementing ordinances are still to follow. The enacted text and ordinances are the authoritative sources. Professional parties can reach the contact form at ownmore.world/contact; qualified investors can access the platform at /access.