FINMA Launches AMLO-FINMA Revision Consultation: What Swiss Financial Intermediaries Must Act On Now

Switzerland's Financial Market Supervisory Authority opened a public consultation on 12 May 2026 for a partial revision of its Anti-Money Laundering Ordinance, known as the AMLO-FINMA. The window closes on 9 June 2026, giving financial intermediaries, their compliance officers, and advisers fewer than four weeks to respond. The proposed changes tighten three areas that directly affect how firms document clients, screen against sanctions, and handle correspondent banking: beneficial ownership identification, embargo-related preventive measures, and transitory-account payment controls. Firms relying on robust crypto compliance reporting workflows should treat this consultation as a structural prompt to audit their current AMLO-FINMA mapping immediately.

Why FINMA Is Revising the Ordinance Now

Three Drivers Behind the Consultation

FINMA identifies three distinct reasons for the revision. First, Switzerland's overarching Anti-Money Laundering Act itself has been amended, and the subordinate ordinance must align. Second, the Financial Action Task Force has issued updated recommendations that Switzerland is obliged to implement. Third, supervisory practice has evolved in ways that have never been formally codified, creating gaps between what FINMA expects in practice and what the written rules actually say. Bringing those expectations into the text removes ambiguity and gives intermediaries a clearer compliance target.

For firms that already track FINMA sanctions obligations for Swiss financial intermediaries, this revision sits in the same enforcement ecosystem and carries comparable urgency.

The Three Core Proposed Changes

Beneficial Ownership: Understanding Ownership and Control

The revised ordinance would require financial intermediaries to be in a position to understand the full ownership and control structure of each customer. This is not simply about collecting a beneficial owner declaration on file; it requires active comprehension of layered structures, including those involving legal entities, trusts, and nominee arrangements. The obligation to obtain a declaration on the beneficial owner is also extended to situations where a contracting party maintains sub-accounts for individual clients, a scenario common in asset management and fund administration.

In practice, this means client onboarding workflows need to capture structural documentation, not just a signature on a standard form. Firms using crypto bookkeeping software or digital asset accounting software to manage client portfolios should confirm that their underlying data models can store and retrieve ownership-chain records at the level of granularity FINMA now contemplates.

Embargo Act: Preventing Breaches of Coercive Measures

The proposed text sets out, in considerably more detail than current rules, the steps intermediaries must take to prevent breaches of coercive measures under Switzerland's Embargo Act. While the existing framework already obliges firms to screen against sanctions lists, the revision codifies specific preventive measures rather than leaving implementation to internal policy discretion. This is a shift from principle-based expectation to rule-based obligation, and it reduces the room firms have to interpret their own obligations.

The blockchain analytics data quality due diligence questions that apply to on-chain transactions become especially relevant here, since the quality of screening outputs is only as reliable as the underlying data. Any gaps in attribution or entity identification could expose a firm to inadvertent embargo breaches under the more prescriptive standard.

Correspondent Banking: Transitory Accounts and Client Information

The third area addresses correspondent banking relationships, specifically transitory accounts. Under the proposed revision, a financial intermediary may only execute payments on behalf of a customer's underlying clients if it has assurance that the customer will supply the necessary client information upon request to allow the intermediary to fulfil its own due diligence duties. This places an explicit information-flow obligation on the correspondent relationship, rather than allowing intermediaries to rely on the correspondent bank's own KYC as sufficient.

For Swiss institutions operating correspondent networks, this will likely require contractual updates to correspondent agreements to include enforceable information-provision clauses.

Practical Compliance Steps Before 9 June 2026

Immediate Actions for Compliance Teams

The consultation deadline is tight. Firms that want to submit a formal response must act quickly, but even those that do not submit a response need to begin gap analysis now, because the revised rules will almost certainly be adopted in substantially the form consulted on. Below is a prioritised action list based on the three areas above.

• Beneficial ownership gap analysis: Review current onboarding procedures against the proposed obligation to understand, not just record, ownership and control structures. Identify client segments where sub-accounts exist and confirm beneficial owner declarations are in place for each underlying client.
• Embargo controls review: Map existing sanctions screening procedures against the more prescriptive measures FINMA is proposing. Identify any policy gaps where internal discretion currently fills a space the revised ordinance would codify.
• Correspondent banking contract audit: Identify all correspondent relationships involving transitory accounts. Review whether existing agreements contain enforceable obligations requiring the customer to supply client information on request.
• System and data readiness: Assess whether current crypto accounting software or digital asset accounting software can capture and surface the ownership-chain and client-level data the revised ordinance will require.

What This Means for the Broader Swiss Digital Asset Sector

Implications for Virtual Asset Service Providers

Switzerland has long positioned itself as a crypto-friendly jurisdiction, but that openness has always come with the expectation of rigorous compliance. The AMLO-FINMA governs financial intermediaries broadly, which includes virtual asset service providers operating under FINMA supervision. The tighter beneficial ownership rules and the codification of embargo preventive measures are directly relevant to any VASP that onboards legal entity clients, operates wallet services with sub-account structures, or routes payments through correspondent relationships.

The direction of travel mirrors what regulators in other jurisdictions are doing. The codification of supervisory practice into binding rules is a pattern visible across European AML reform, and Swiss VASPs that are already benchmarking their compliance frameworks against international standards will find the proposed AMLO-FINMA changes largely consistent with that direction, even if the specific Swiss legal form differs.

FAQs

What is the AMLO-FINMA and who does it apply to?

The AMLO-FINMA is FINMA's Anti-Money Laundering Ordinance. It specifies how financial intermediaries supervised by FINMA, including banks, securities firms, fund managers, and virtual asset service providers, must implement the requirements of Switzerland's Anti-Money Laundering Act to prevent money laundering and terrorist financing.

When does the consultation close and how can firms respond?

The consultation period runs from 12 May 2026 to 9 June 2026. Firms wishing to submit a formal response should do so directly through FINMA's published consultation process, details of which are available on FINMA's official website.

What is the new sub-account beneficial owner declaration requirement?

Under the proposed revision, a financial intermediary must obtain a beneficial owner declaration even where a contracting party maintains sub-accounts for individual underlying clients. This closes a potential gap where the intermediary knew only the top-level account holder but not the individuals beneficially entitled to assets held in sub-accounts.

How do the correspondent banking changes affect transitory accounts?

The revision stipulates that, for transitory accounts in correspondent banking relationships, an intermediary may only execute payments on behalf of a customer's clients if it has ensured that the customer will provide the client information necessary for the intermediary's own due diligence duties upon request. This requires explicit contractual arrangements with correspondent partners.

Does this revision affect digital asset or crypto firms specifically?

Yes. Virtual asset service providers supervised by FINMA are financial intermediaries within scope of the AMLO-FINMA. The beneficial ownership, embargo, and correspondent banking changes apply equally to them, and firms using crypto accounting software or digital asset accounting software should verify that their systems can support the more granular documentation requirements the revision introduces.

Source: FINMA