The Swiss banks’ due diligence agreement has existed for decades; the current version is CDB 20. It is a self-regulation of the Swiss Bankers Association that banks enter into among themselves and with the association. FINMA recognises it as a minimum standard. In substance it specifies the identification duties that the Anti-Money Laundering Act states in general terms.
What it regulates
Essentially three things: identifying the contracting party with admissible documents, establishing the controlling persons of operating companies and establishing the beneficial owners of assets. It adds rules for special cases such as domiciliary companies, trusts, foundations, life insurance with separate account and custody management, and accounts of professionals bound by secrecy, as well as when information must be obtained again, for example in case of doubt.
The forms
CDB 20 contains model forms that banks use directly or in equivalent form: Form A for beneficial owners, Form K for controlling persons, Form T for trusts, Form S for foundations and Form I for insurance wrappers. Many self-regulatory organisations have adopted comparable forms.
Who rules on breaches
A supervisory board assesses suspected breaches and can impose contractual penalties. The association publishes its anonymised decisions twice a year as leading cases. That collection is the best source for how the rules are applied in practice, for example which details a form may omit and which it may not.
Why it matters beyond banks
Fiduciaries, family offices and independent asset managers meet CDB 20 every time they open accounts or restructure for clients. The bank requests the forms, the family office supplies the information. Knowing the logic speeds up account openings and avoids follow-up questions. Keeping mandate data so that controlling persons, beneficiaries and founders are documented at all times does the work for every bank at once.