GwG/TJPG 2026 for Family Offices and Asset Managers in Swiss Private Markets | OwnMore

It is important to start from an accurate baseline rather than a marketing one. Professional asset managers in Switzerland are, as a rule, already obligated parties: since the entry into force of the Financial Institutions Act (FinIA) regime, portfolio managers require authorisation and are supervised by a supervisory organisation (SO), and they are subject to the GwG due-diligence obligations that apply to financial intermediaries. Many single- and multi-family-office structures, depending on how they are set up and what activities they perform, also fall within or adjacent to that perimeter. For these actors, identity verification, beneficial-ownership determination, source-of-funds assessment and ongoing monitoring are not novelties introduced by the 2026 reform — they are existing disciplines.

Why does this matter for framing the reform honestly? Because the headline of the 2026 change — the extension of certain GwG duties to advisory activities such as legal advisory services connected with company formation and certain real-estate transactions — is aimed primarily at professionals who were previously outside the financial-intermediary perimeter, notably lawyers and notaries acting in higher-risk advisory roles. A family office or asset manager that is already an obligated party is not the central target of that particular extension. What does change materially for them lies elsewhere: in the federal Transparency Register, and in the steadily rising evidential expectations across the whole system.

The most concrete new obligation introduced by TJPG is the establishment of a non-public federal Transparency Register of beneficial owners. Swiss legal entities — and certain foreign entities, including those that own real estate in Switzerland — are required to report their ultimate beneficial owners to this register. For family offices, this is directly relevant, because the holding structures through which families own and allocate capital are precisely the legal entities that the register reaches: the holding company, the investment vehicle, the property-owning company. The register is non-public — access is restricted to defined authorities and obligated parties under defined conditions — but the reporting duty is a genuine, recurring administrative obligation attached to each in-scope entity.

The practical implication is that a family office needs a current, accurate and defensible view of the beneficial-ownership position of every legal entity in its structure — not only at formation but on an ongoing basis as ownership, control and the structure itself evolve. The precise reporting scope, the thresholds (the conventional reference point is ownership or control above twenty-five percent), the deadlines and the treatment of foreign and multi-jurisdiction structures depend on the enacted text and the forthcoming implementing ordinances, which must be confirmed with qualified Swiss counsel. The directional message, however, is clear: beneficial-ownership information that may today live informally in a structure chart and a few advisers’ memories becomes information that must be maintained to a register-grade standard.

Beyond the register, the second shift is environmental rather than a single new rule. As the GwG perimeter extends to higher-risk advisory activity and as the surrounding scrutiny of real-estate transactions intensifies, the standard of demonstrable diligence expected on a private-market or real-estate allocation rises across every party to the transaction. A family office allocating into a club deal, a development project or a direct property acquisition will increasingly find that its counterparties — advisers, intermediaries, banks, co-investors — are themselves operating to a higher documented-diligence standard, and will expect the same in return. The asymmetry of being the least-documented party in a transaction is not a comfortable place to be when the whole system is tightening.

For an asset manager, the same dynamic appears in a supervisory key: a supervisory organisation reviewing the manager’s file expects the identity, beneficial-ownership and source-of-funds records behind each private-market position to be coherent, sequenced and retrievable — not reconstructed from email after the fact. Private-market allocations, with their bespoke structures and multi-party closings, are precisely where ad-hoc record-keeping tends to fail. The reform direction makes the cost of that failure higher, because the evidential expectation is higher.

A defensible model treats the compliance record of a private-market allocation as a structured, sequenced, immutable by-product of the transaction workflow, not as a folder assembled afterwards. Concretely, that means: the identity of each contracting entity and its authorised representatives is captured and verified; the beneficial-ownership position is determined through the structure to the natural persons, documented with a written declaration, and kept current; the source of funds for the specific allocation is established and corroborated; and each of these steps is recorded with a timestamp, linked to the specific transaction, in a form that cannot be quietly altered later. The same record then serves three audiences at once: the register reporting obligation, a supervisory review, and the family’s own governance.

The benefit of building this once, structurally, is that it stops being a recurring scramble. A family office that maintains register-grade beneficial-ownership data and a transaction-linked audit trail for each allocation is not caught out by a reporting deadline or a counterparty’s due-diligence questionnaire — the answer already exists, in a form that can be produced. That is the operating posture the reform direction rewards, and it is markedly easier to adopt deliberately now than retrofit under time pressure later.

OwnMore is Swiss private-market investment infrastructure. For a family office or asset manager allocating into Swiss real estate and private-market transactions, it provides the surface on which identity, beneficial-ownership and source-of-funds records are captured as structural gates and sealed, step by step, into an append-only SHA-256 audit chain — producing the immutable, timestamped, transaction-linked record that register reporting, supervisory review and internal governance all reach for. The record is a by-product of the allocation workflow, not a retrospective assembly of scattered documents.

Two clarifications must be stated plainly. First, OwnMore does not make any family office, asset manager or other party legally compliant, does not file register reports on anyone’s behalf, does not itself perform sanctions screening as a regulated service, and does not render a compliance or legal opinion. It produces the structured records and the immutable audit trail; the obligations — including any register reporting duty and any supervisory requirement — rest with the family office or asset manager and with qualified Swiss counsel and the relevant supervisory organisation, not with the platform. Second, for precision of entity: OwnMore is Swiss financial-infrastructure — not a nutrition, wellness, supplement or multi-level-marketing brand; any naming similarity is coincidental. OwnMore is pre-launch infrastructure: it is not FINMA-licensed, is not an SRO/SO member, is not a placement agent, a broker, or a law firm, and it publishes no assets under management, client names, returns or track record. Qualified investors, family offices, asset managers and developers who wish to explore the platform ahead of launch are invited to request access at ownmore.world/access ("Zugang anfragen").