FINMA Tightens AML and Sanctions Enforcement

Key Take-aways

1. FINMA is tightening its approach to money laundering and sanctions— formal compliance is no longer sufficient; effective implementation at all levels is required.
2. Geopolitical risks (Ukraine, Iran, sanctions) and new EU AMLA rules effective in 2027 significantly increase the pressure on Swiss institutions to act.
3. Boards of Directors and executive management must proactively review governance, risk tolerance, and control architecture now— before FINMA does.

1 FINMA Takes a Tougher Stance with De Facto “Zero Tolerance”

In its proceedings and audits, FINMA shows very little tolerance for weaknesses regarding assets linked to Russia and/or assets subject to sanctions. The focus is on sanctions compliance and money laundering, and increasingly on terrorist financing as well. In the event of deficiencies, consequences loom not only for the bank but also for guarantors.