FINMA Guidance 04/2026: Further Precision On AML Risk Analysis

A stronger supervisory focus on risk tolerance, indicators and governance

On 4 June 2026, FINMA published Guidance 04/2026 on AML risk analysis under Article 25 para. 2 of the FINMA AML-Ordinance. The Guidance is relevant because it turns the AML risk analysis into a practical benchmark for supervision, audit findings, remediation and potential enforcement exposure. It clarifies how FINMA expects banks and financial institutions subject to the Financial Institutions Act (FinIA) to define money laundering risk tolerance, use meaningful indicators, assess inherent, control and net risks, and then escalate breaches into management action.

Supervisory background

The obligation to prepare an AML risk analysis follows from Article 25 para. 2 of the FINMA AML-Ordinance. On this legal basis, FINMA had already reviewed the AML risk analysis of more than 30 banks in Spring 2023 published Guidance 05/2023 on 24 August 2023 and thereafter issued Guidance 04/2026 after re-reviewing a segment