Why the reform reaches you as the investing party
The Swiss Anti-Money-Laundering Act (GwG) obliges financial intermediaries — platforms, brokers, managers — to know who they are dealing with. As the investing party, you are not a passive participant: you are the counterparty being identified, whose ownership structure is looked through, and whose capital is examined for its origin. This model has been established for years; the 2026 AML reform sharpens it further.
The purpose is preventive: the financial system should not be a conduit for money laundering or terrorist financing. For the private-market investor, this means checks happen before any binding step — before a reservation becomes binding, before capital moves, before documents are signed. A serious platform makes this gate structural. The reform now raises the requirements for transparency and documentation along the entire chain — and with them, the requirements you as the investing party will be expected to meet.
It is worth keeping the classification side cleanly separate: classification as a qualified investor under FinSA (the Financial Services Act) governs whether a non-public offering may lawfully reach you at all. GwG onboarding then governs whether the relationship may be entered and the funds accepted. Both gates must be cleared before the first binding step. The companion article on qualified investors in Switzerland covers the FinSA classification framework — this article focuses on the GwG side and what the 2026 reform concretely changes for you.
What LETA actually changes — timeline and what is already in force
The federal act on the transparency of legal entities and the identification of beneficial owners (LETA) was adopted by the Swiss parliament on 26 September 2025. Entry into force is expected in H2 2026; no fixed date has been set, as the implementing ordinances are still outstanding. For planning purposes: the reform is enacted, the precise timing is open. Preparing clean structures and documentation now is not premature — it is prudent.
The core of LETA for investors: a non-public transparency register for beneficial owners. The reporting obligation falls on the obligated entities (companies, trusts and comparable structures) — not on the investor as such. The threshold is a direct or indirect interest of 25 % or the exercise of control; the register is not publicly accessible, but available to authorities and supervisory bodies. A CHF 5 million threshold was discussed during the legislative process but has not been enacted and should not be treated as applicable law.
LETA supplements and tightens the existing GwG regime: the obligation to determine beneficial owners already existed; LETA formalises the registration and creates an authority infrastructure behind it. For you as an investor, the practical implication is that the diligence a financial intermediary applies when establishing your UBO chain will continue to increase with the reform — and that clean, current UBO documentation is not a burden but an accelerator in any onboarding process.
Your beneficial-ownership declaration — what a clean UBO chain looks like
If you invest through a structure — holding company, foundation, trust, SPV — the GwG requires the financial intermediary not just to identify the entity but to determine the natural persons behind it. That is the look-through: the chain is traced to the natural persons who hold 25 % or more of the shares or voting rights, or who otherwise control the entity. For foundations and trusts it means looking through to the controlling persons and beneficiaries.
The investing party typically confirms this in a written UBO declaration (declaration of beneficial ownership). What makes a clean declaration: complete and current details on all natural persons who reach the 25 % threshold or exercise control; commercial register extracts and constitutional documents for each layer of the structure; powers of attorney and authorised signatories for the acting persons; and an update whenever the ownership structure changes. A family office with several holding layers should be able to document the full chain without gaps — a task that is manageable with good preparation but easy to stall under time pressure.
With LETA, the formalisation of this chain increases: the obligation to report to the transparency register rests with the entities themselves, but the financial intermediary will align its clarifications with the reported and documented data. Keep your UBO documentation current — not just for the next onboarding, but as an ongoing element of your investor administration.
Your source-of-funds evidence — what tends to be asked and how good preparation helps
Alongside identification and UBO determination, the financial intermediary must establish the origin of the funds. The depth of this inquiry scales with the risk of the relationship: a straightforward relationship with an obvious, documented source of wealth requires less than one presenting elevated risk — for example where a beneficial owner is a politically exposed person (PEP), where the structure spans high-risk jurisdictions, or where the transaction size or pattern is unusual.
Typically requested documents for source-of-funds evidence: asset overviews or annual accounts of the holding company or the investor; documentation of the origin of larger capital inflows (sale proceeds, inheritance, dividends, capital reserves); tax adviser or auditor certificates; for foundations and trusts the constitutional documents and origin of the foundation assets. There is no exhaustive statutory list — the intermediary decides proportionally to risk which evidence it requires. Investors who are well prepared can deliver these documents from an organised file rather than scrambling under time pressure.
The 2026 AML reform and LETA strengthen the expectation of complete, traceable documentation. This is not bureaucratic excess: a plausible, fully evidenced source of funds protects you and the transaction from delays — and signals to the intermediary that your structure is run transparently and in compliance. Good preparation turns onboarding from a hurdle into an efficient process.
Why a structured onboarding gate protects you too
A common misconception: GwG onboarding is an obligation of the financial intermediary, not a service for the investor. That is legally correct — the obligated entities bear the due-diligence duties. In practice, however, a cleanly documented onboarding file, completed in the correct sequence, has considerable value for you as the investing party too: it evidences that the relationship was legally permissible when entered, that your funds were reviewed and accepted, and that every later transaction rests on a verified foundation.
The opposite — a stake reserved or signed before onboarding is complete — sits on unstable ground. The relationship may not yet have been permissible to enter, the funds may not yet have been acceptable to receive. If the problem surfaces years later under an audit or regulatory proceeding, it is considerably harder and more costly to resolve than a complete gate at the outset. The structural gate is not bureaucracy imposed on you — it is a protection that serves everyone involved.
LETA formalises the registration obligation of companies; the obligation to be able to document your structure and source of funds cleanly at any time is timeless. Investors who keep their UBO documentation and source-of-funds evidence consistently up to date stand on solid ground in every onboarding and every audit — regardless of when an ordinance enters into force.
How OwnMore fits as infrastructure within this framework
OwnMore is self-directed infrastructure for private-market investments in Swiss real estate. That means the investor acts in their own name throughout. OwnMore provides the gate and the record — not a decision on the investor’s behalf. Identity, beneficial ownership and source-of-funds evidence are captured and recorded as a structural gate before any binding stage unlocks. This sequence — classified, onboarded, then admitted to the opportunity — is sealed into an append-only SHA-256 audit chain, so that the evidence of a properly entered relationship sits alongside every later action.
Two clarifications matter. First: OwnMore is not a FINMA-licensed financial intermediary, SRO member or broker. SRO affiliation, custody and screening infrastructure are in preparation (pre-launch). OwnMore makes no one legally compliant — it operationalises the GwG framework as an infrastructure gate, but does not set the rules and does not replace qualified Swiss legal advice. Second: OwnMore is pre-launch and publishes no assets under management, client names, returns or track record.
Access to the platform follows a structured entry path that maps classification, onboarding and admission in the correct sequence. If you as an investor or family office would like to understand how OwnMore as infrastructure fits your situation, you can request a conversation via the contact form or go directly to the access path. This article is educational and is not investment, tax or legal advice.