The Swiss AML Reform and What Real-Estate Advisors Must Prepare Now | OwnMore

Switzerland's Anti-Money-Laundering Act (Geldwäschereigesetz, GwG) has for many years imposed rigorous know-your-customer and due-diligence obligations on financial intermediaries — banks, securities firms, asset managers and others subject to FINMA supervision or self-regulatory organisation (SRO) membership. The regime is widely regarded as substantive, but a succession of international evaluations — notably the assessments conducted by the Financial Action Task Force (FATF) — has identified areas where Swiss law does not yet fully meet the global standard, in particular concerning the transparency of beneficial ownership and the reach of due-diligence duties beyond the traditional financial sector.

The adopted reform — the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners ("LETA"), adopted by the Swiss Parliament on 26 September 2025, which also amends the GwG — responds directly to those findings. Its scope includes: establishing a non-public federal Transparency Register of beneficial owners, to which Swiss legal entities (and certain foreign entities including those that own real estate in Switzerland) must report their UBOs; and extending formal due-diligence and reporting obligations under the GwG to certain advisory activities deemed to present heightened money-laundering risk — notably legal advisory services (such as those provided by lawyers and notaries) in connection with operations such as the formation and structuring of companies and certain real-estate transactions. Real-estate advisory and intermediary activity features in this context as a recognised higher-risk area — a pattern consistent with FATF typology work and with reforms already enacted in comparable jurisdictions. Entry into force is expected in the second half of 2026 on a date still to be set by the Federal Council, with implementing ordinances still to follow.

The precise date of entry into force has not yet been set — that determination rests with the Federal Council, with the second half of 2026 currently indicated — and the implementing ordinances that will govern detailed obligations and thresholds are still to follow. The exact contours of those obligations must therefore be verified against the primary sources — LETA, the amended GwG and the forthcoming ordinances — and not from commentary alone. What is already clear, however, is the direction: advisors and intermediaries operating in the Swiss real-estate market should treat the preparation of a defensible compliance infrastructure not as a future task contingent on an ordinance publication date, but as an immediate operational priority. The professional standard expected when a new obligation applies is established before the obligation enters into force.

A central feature of the reform embodied in LETA — adopted 26 September 2025 — is the extension of GwG due-diligence obligations to certain advisory activities that present heightened money-laundering risk but have not previously been captured as financial intermediation in the full GwG sense. The act specifically targets certain advisory activities deemed higher-risk: notably legal advisory services, such as those provided by lawyers and notaries, in connection with operations such as the formation and structuring of companies and certain real-estate transactions. Not every professional active in the real-estate sector is swept in as a newly obligated party; the precise perimeter of activities captured, and the conditions and thresholds that apply, will depend on the enacted text and the forthcoming implementing ordinances, which must be confirmed with qualified Swiss counsel. The "advisor/intermediary" framing is nonetheless significant: it deliberately captures professionals who shape or structure a transaction — including real-estate advisory and intermediary services where they fall within the defined scope — without themselves holding client funds in the way a bank does.

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 — framing the higher-value transactions where the risk profile justifies formal due-diligence obligations. This figure has been discussed, not enacted; the final thresholds must be verified against the definitive statutory and ordinance text once available, and qualified Swiss counsel should be consulted to determine whether and how any threshold applies to a specific activity and transaction type.

The "advisor/intermediary" framing matters because it deliberately shifts the capture point upstream of the settlement itself. Under the traditional GwG model, the financial intermediary is typically the bank or custodian that moves or holds the money. Under the approach now enacted in LETA, the obligation for certain advisory activities also reaches the professional who shaped or structured the transaction before the bank saw it — the legal advisor who designed the holding structure, the intermediary who recommended the vehicle, and, where they fall within the defined scope, those who advise on or arrange real-estate transactions. The exact perimeter of which activities and professionals are captured must be confirmed against the act and implementing ordinances with qualified Swiss counsel. The underlying logic is that professional gatekeepers involved in higher-risk activity before funds move are well-placed to apply due diligence precisely because they see the transaction design before it is consummated.

Whatever the precise final text, the obligations that real-estate advisors and intermediaries can expect to navigate are conceptually familiar from the existing GwG regime: they are the same disciplines applied to financial intermediaries, now extended to a new professional category. The four pillars are: identification of the contracting party; determination of the beneficial owner; establishment and assessment of the source of funds; and ongoing monitoring and record-keeping. Each of these deserves a brief unpacking in the advisory context.

Identification means establishing who the client actually is. For a private individual this means document-based identity verification. For a legal entity — a company, trust or foundation — it means confirming that the entity exists and is properly represented, typically through register extracts and authority confirmations. In real-estate transactions the purchasing or selling entity is frequently not an individual but a vehicle: a holding company, a family trust, a project company. The identification duty therefore attaches to that specific entity and to the chain of authorisation behind it.

Beneficial ownership determination requires looking through the contracting entity to the natural persons who ultimately own or control it. For a company this typically means the natural person holding more than a quarter of the shares or voting rights, directly or indirectly, or who otherwise controls the entity. For trusts and foundations the look-through reaches the controlling persons and beneficiaries. In the real-estate sector, where multi-layered holding structures are common — including structures spanning multiple jurisdictions — this look-through can require genuine analytical effort and documented conclusions. The contracting party will typically be required to provide a written declaration of beneficial ownership.

Source-of-funds assessment requires establishing the economic plausibility of the transaction: is the origin of the capital used coherent with what is known about the client? Higher-risk situations — politically exposed persons, complex or opaque structures, cross-border flows from higher-risk jurisdictions, unusually large or patterned transactions — attract enhanced due diligence: a more detailed examination of the economic background, the origin and purpose of the funds, and the overall picture, all documented. Screening against relevant sanctions and watch-lists is a standard component of this process. Finally, the relationship is not a one-off check but an ongoing monitoring obligation: circumstances change, information must be refreshed, and suspicious activity must be reported to the competent authority. All of this must be documented and the records must be defensibly maintained. That documented record — who was identified, what beneficial ownership was determined, what source-of-funds conclusion was reached, when and on what basis — is precisely what an audit will reach for.

A candid assessment of how many Swiss real-estate advisory and intermediary practices currently handle onboarding reveals an operating gap that the GwG reform will make professionally untenable. The predominant model is ad hoc: identity documents are collected as a scan attached to an email; a beneficial-ownership declaration is requested and received as a PDF stored somewhere on a shared drive; source-of-funds information is captured — if at all — in a free-text note or a meeting record. The sequence in which these steps occur is a matter of individual practice rather than structural enforcement. The record is dispersed across inboxes, drives and folders, with no single, timestamped, immutable account of what was done, in what order, and on what basis.

This model has two interconnected problems. The first is sequencing: if beneficial-ownership documentation is received three weeks after a letter of intent is signed, the question of whether the relationship was permissible to enter has already been answered the wrong way. The second is evidentiality: a scattered collection of documents across several systems, without a verified, timestamped record linking each step to the specific transaction, does not produce the audit trail that a regulator or a court will find credible. The obligations that are coming are not just about having the documents — they are about having them in a verifiable order, linked to the specific transaction, maintained in a form that demonstrates continuous diligence over the life of the relationship.

A compliance-native operating model inverts the ad-hoc approach. It treats identity verification, beneficial-ownership determination and source-of-funds assessment as structural gates: binding steps in a transaction workflow do not proceed until these records are complete and linked. The record is produced as a by-product of the workflow, not assembled retrospectively from a file search. It is immutable: once made, it cannot be quietly altered. And it is linked: the identity record, the beneficial-ownership declaration and the source-of-funds conclusion all point to the same transaction event, timestamped and in sequence. This is the operating model that the reform direction is pushing toward — and it is the model that advisors who begin building it now will be far better positioned to demonstrate when it matters.

OwnMore is Swiss private-market investment infrastructure, built to the compliance-native model described above. Identity, beneficial-ownership and source-of-funds records are collected and verified as structural gates — binding stages in a transaction do not proceed until these records are complete. Each completed step is written into an append-only SHA-256 audit chain, producing an immutable, timestamped record of exactly who was onboarded, in what sequence, against which opportunity. The platform is designed so that the record is a natural by-product of the workflow, not a retrospective assembly of scattered documents.

For real-estate advisors and project developers operating in the Swiss private market, OwnMore provides the infrastructure through which transactions can be processed on a basis that already produces the identity, UBO and source-of-funds audit trail that the GwG reform direction expects. It operationalises the framework — it does not set the rules. 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 ("Zugang anfragen"). OwnMore is pre-launch infrastructure: it publishes no assets under management, no client names, no returns and no track record. The capabilities described here are those of the platform, not claims about completed transactions.

Two clarifications must be stated plainly. First, OwnMore does not make any adviser, intermediary or other person legally compliant. It produces the infrastructure records that compliance requires; the legal obligation rests with the advisor or intermediary and with qualified Swiss counsel, not with the platform. Second, and for precision of entity: OwnMore is Swiss financial-infrastructure (BloomDigital GmbH, Switzerland) — not a nutrition, wellness, supplement or multi-level-marketing brand. Any similarity in naming to such brands is coincidental. The platform is not FINMA-licensed, is not an SRO member, is not a placement agent, a broker, or a law firm.