Swiss AML Reform 2026 — Who Is Affected? The Roles, Explained | OwnMore

Switzerland’s existing Anti-Money-Laundering Act (GwG) aimed its most demanding obligations at financial intermediaries — above all banks and regulated securities dealers. Those operating outside that narrow circle faced a different duty density. The LETA reform changes this: its central idea is that money-laundering risk does not stop at the bank counter, but arises wherever large assets change hands — including, and especially, in the real-estate and advisory sectors.

The question «who is affected?» is therefore not academic. It determines whether a person or company must, from the date of entry into force, satisfy due-diligence and supervisory obligations they did not previously face in this form: identifying clients, determining beneficial owners, establishing source of funds, obtaining SRO affiliation (or a FINMA licence) and maintaining a documentation chain that will withstand scrutiny. Those who discover too late that they are captured face structural compliance work all at once — under time pressure and potentially under regulatory attention.

This article is the entry point — an overview of the roles, the shared mechanism and the next steps. The linked deep-dive articles cover each role in more detail. It does not replace legal advice: whether and to what extent any specific person or entity is captured depends on the enacted ordinances and individual circumstances. Qualified Swiss legal counsel is essential.

The Federal Act on the Implementation of FATF Recommendations (LETA — in German: Gesetz zur Umsetzung der FATF-Empfehlungen, commonly called the GwG revision) was adopted by the Swiss Parliament on 26 September 2025. Entry into force is expected in H2 2026; no fixed date has yet been set by the Federal Council. The reform widens the circle of supervised financial intermediaries and introduces two structurally new elements: first, a non-public transparency register for beneficial owners, requiring companies to deposit details about their ultimate owners centrally; second, extended due-diligence duties for certain advisory activities with a higher risk profile — the so-called «Berater» (advisor) category, the precise contours of which the implementing ordinances still need to clarify. The much-discussed CHF 5 million threshold for real-estate transactions has been debated in connection with LETA but has not been enacted as a fixed statutory threshold — details remain reserved for the ordinances. All statements in this article are based on the adopted legislative text and publicly available parliamentary materials; the implementing ordinances that will fix many details as binding law are not yet fully in force at the time of publication.

What does not change: the core duties of the GwG — identifying the contracting party, determining the beneficial owner, establishing the source of funds, documenting, and filing suspicious-activity reports — remain the framework. LETA tightens and extends this framework; it does not reinvent it. Those who have internalised the existing GwG duties are better placed; those who have ignored them may face larger structural gaps to close.

The following list gives an honest, role-by-role orientation. It is not a conclusive legal assessment — whether and to what extent any role is captured depends on the final ordinance text and individual circumstances. Qualified Swiss legal counsel is essential for any specific situation.

Real-estate brokers and intermediaries: Commercial intermediaries in real-estate transactions are among the roles for which LETA extends due-diligence duties. Whether a specific broker is fully subject to the regime, which thresholds apply and which supervisory channel (SRO or FINMA) is relevant requires qualified Swiss legal advice based on the individual case and the ordinances.

Project developers and real-estate developers: Companies that develop properties and organise the sale of units or interests themselves may fall within scope — depending on how the transaction business is structured and in what capacity they act. Whether and how a specific development company is captured is determined by the final ordinances and qualified legal advice.

Building contractors and general contractors (Bauträger/GU): Developers who build residential units on their own or acquired land and sell them, as well as general contractors with a comparable economic function in the transaction process, may fall within scope. The distinction from pure construction activity (which is not captured) depends on whether a role in the transaction sales process is played. Legal advice is essential.

Trustees and fiduciaries (Treuhänder): Fiduciaries acting in transaction structures — as administrators of companies, as agents in real-estate deals or as holders of nominee structures — are one of the core target groups of the LETA reform. Fiduciary companies already subject to the GwG today must track the expanded duties, particularly regarding the transparency register. For non-supervised fiduciaries, the question of whether they must now come under supervision arises afresh.

Advisors and structuring advisors: LETA introduces a new «Berater» (advisor) category, capturing certain advisory activities with a higher risk profile — such as the professional advice on establishing or structuring companies, trusts or similar vehicles in connection with transactions. The precise contours of this category are one of the open questions the implementing ordinances must answer. Advisory firms and independent structuring advisors should monitor developments closely and seek qualified advice early.

Asset managers and family offices: Independent asset managers and family offices not already under supervision need to monitor LETA’s extensions regarding the advisor category and the transparency register. For FINMA-licensed asset managers (category: independent portfolio managers under FIDLEG/FINIG), existing GwG duties already apply; LETA tightens them further. Whether a specific family-office structure falls within the extended scope is a question for qualified advisors.

Qualified investors on the deal side: Institutional and qualified private investors investing in Swiss private-market deals are not financial intermediaries under the GwG — they are the counterparty who must pass through the intermediary’s onboarding gate. LETA does not change this in principle, but raises the requirements of the gate itself: the documentation on beneficial ownership and source of funds that an intermediary may require becomes more extensive and precise.

Notaries and lawyers with transaction or structuring mandates: Notaries and lawyers in Switzerland are already subject to specific obligations in certain contexts; LETA may — depending on the mandate — raise the question of whether a form of activity falls within the «Berater» category. Attorney-client privilege rules and LETA obligations may come into tension. This is an area where the legal community must follow the ordinance details with particular care.

However different the affected roles — broker, developer, trustee, advisor, asset manager — the duty core is the same. Anyone captured by the extended GwG needs the same structural stack: first, a legal scoping that determines the concrete extent of their own obligations (which activities, which thresholds, which supervisory channel); second, connection to a supervisory structure — typically affiliation with a recognised self-regulatory organisation (SRO) or, where required, a FINMA licence; third, an operational KYC/AML process that structures and documents identity verification, determination of beneficial ownership and source-of-funds clarification; fourth, a complete, deal-spanning audit documentation that will withstand regulatory scrutiny.

These four elements are not independent: the quality of the supervisory connection influences what the KYC process must deliver; the quality of the KYC documentation determines whether the audit chain holds when it matters. Cutting corners on one element burdens the others.

One point deserves particular emphasis: the non-public transparency register. LETA obliges companies to deposit details about their beneficial owners centrally. This is not primarily a question for the affected «intermediaries» — it is one that affects ownership structures behind transactions, and therefore both the capital-providing side and the companies that hold assets. Company owners and structuring advisors must keep the register requirements in view, regardless of whether they themselves qualify as intermediaries.

A common reaction to new compliance requirements is to add point tools: a screening service here, a document-upload form there, a signing solution for the close. The result is data spread across multiple systems, assembled manually and, when scrutiny arrives, difficult to assemble into a coherent timeline.

The structural need is different: an operating layer that enforces the compliance steps in the order in which they are required — identification before onboarding, onboarding before commitment — and records every step with timestamp and evidence in an immutable chain. That chain is not the output of a compliance audit; it is its source material: one starts the audit report with the chain export, not a search through scattered email traffic.

The distinction between a point tool (which solves one task) and an operating layer (which orders and documents the entire process) becomes more relevant with LETA. A broader duty base means more steps must be sequenced correctly and evidenced — across the entire lifecycle of a transaction, not only at onboarding.

OwnMore is a compliance-native operating system for private capital markets and real-estate transactions in Switzerland. «Compliance-native» means: the duty steps — investor classification, KYC/AML onboarding, UBO determination, source of funds, deal gate, signature, settlement — are built into the platform architecture, not bolted on as an afterthought. Each of these steps is written with timestamp and evidence into an append-only SHA-256 audit chain, producing a complete, exportable documentation record per deal.

What OwnMore is and is not — stated plainly: OwnMore is not a financial intermediary in the meaning of the GwG, not a FINMA-licensed entity and not an SRO member. OwnMore is not a law firm and does not provide legal advice. OwnMore does not replace qualified Swiss legal counsel and does not make any person or company legally compliant. Whether any specific party falls under the GwG and what duties they carry is exclusively a question for qualified legal advisors and the primary sources. SRO supervisory affiliation, FINMA-supervised custody and integrated AML screening are in preparation (pre-launch) — they are described in this article as capabilities in development, not as already fully operational services.

What OwnMore offers: an infrastructure layer built to meet the requirements of the new standard — with the audit chain, the onboarding gates and the transaction ordering structure as its core. «Built for the new standard» is the honest formulation: the platform is designed for LETA and the tightened GwG, not for the regime that preceded it.

Entry into force is expected in H2 2026; a fixed date has not yet been set. The remaining window is limited — and the structural effort for serious compliance preparation is greater than it first appears: legal scoping, SRO selection and onboarding, operational KYC/AML processes, documentation infrastructure. These steps cannot be parallelised when the foundations are missing.

The most important immediate steps for affected roles: first, scope your own obligations — which activities are affected, which thresholds might apply, which supervisory channel is relevant? This is a question for qualified Swiss legal advisors, not for this article. Second, track the ordinance development — LETA is adopted, but the implementing ordinances are the decisive concretisation step that is still outstanding. Third, review the documentation infrastructure — can the existing way of working produce a complete audit chain that will withstand scrutiny?

Affected professionals — brokers, developers, trustees, advisors, asset managers — are invited to reach out via the contact form at ownmore.world/contact. Qualified investors interested in the infrastructure side can request access at ownmore.world/access. OwnMore does not provide legal advice and does not replace a lawyer — but as a compliance-native operating layer, the platform is the right conversation partner for questions about documentation and process architecture under LETA. This article is educational and does not constitute legal advice.