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ARTICLE · 22 MAY 2026

Partial Revision Of The AMLO-FINMA

Schellenberg Wittmer Ltd
Schellenberg Wittmer Ltd
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Schellenberg Wittmer Ltd

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SwitzerlandGovernment, Public Sector
Dr. Philippe Borens
Dr. Philippe Borens
Caroline Clemetson
Caroline Clemetson
Olivier Favre
Olivier Favre
Tarek Houdrouge
Tarek Houdrouge
Anita Schläpfer
Anita Schläpfer
Grégoire Tribolet
Grégoire Tribolet
Grégoire Wuest, LL.M.
Grégoire Wuest, LL.M.
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On 12 May 2026, FINMA launched the consultation on a partial revision of the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA). The consultation runs until 9 June 2026 — a deliberately short timeframe that FINMA justifies in light of Switzerland’s fifth-round FATF mutual evaluation scheduled for 2026–2027. The amended ordinance is expected to enter into force on 1 January 2027, in parallel with the revised Swiss Bankers Association Code of Conduct (CDB) and the revised rulebook of the self-regulatory organisation of the Swiss Insurance Association (SRO-SIA / SRO-SVV).

Drivers of the revision

FINMA identifies three main drivers for the revision: (i) the revised Anti-Money Laundering Act (AMLA), adopted by Parliament on 26 September 2025 together with the new Federal Act on the Transparency of Legal Entities; (ii) the need to address residual deficiencies identified in Switzerland’s fourth FATF mutual evaluation report and the fourth Enhanced Follow-up Report ahead of the

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