In 2024 the European Union reorganised its anti-money laundering law. At its heart is Regulation (EU) 2024/1624, the AMLR, which essentially applies directly in all member states from 10 July 2027. Alongside it come Regulation (EU) 2024/1620 establishing the new AMLA authority in Frankfurt and the sixth Anti-Money Laundering Directive. Switzerland is bound by none of it. For Swiss family offices and trustees with cross-border mandates, the package is nonetheless one of the most important regulatory topics of the next two years.
What changes in the EU
Until now each member state transposed the anti-money laundering directives its own way. From 2027 the core obligations apply directly and uniformly as a regulation: who is obliged, which due diligence duties apply, when simplified and when enhanced measures apply, how to deal with politically exposed persons, which internal controls are needed. There is also an EU-wide limit of EUR 10,000 for cash payments in trade.
Most important for family structures are the rules on beneficial owners. Ownership is assumed from 25 percent or more; control can also exist by other means. The Regulation contains detailed requirements for multi-layered structures and for trusts and similar legal arrangements. For higher-risk categories the Commission can set lower thresholds.
Three routes by which the AMLR reaches Swiss actors
The first route is direct: companies, trusts and accounts in the EU are subject to EU law. A family with a holding in Luxembourg, a property company in Germany and a trust with an Irish trustee has three parts of its structure to which uniform rules apply from 2027.
The second route is indirect and acts earlier: EU banks, custodians and service providers implement the new requirements and pass them on to their counterparties. AMLA develops technical standards that align expectations. Swiss family offices and independent asset managers working with EU institutions will notice the AMLR first in those institutions’ questionnaires.
The third route runs through Liechtenstein. As an EEA state, Liechtenstein takes over EU anti-money laundering law via the EEA Agreement. Anyone administering Liechtenstein foundations or companies should follow when and how the AMLR is incorporated there.
Switzerland and the EU side by side
Since 1 October 2026 Switzerland has its own transparency register under the TJPG and extended duties under the revised AMLA. The logic is related — 25 percent, control by other means, a fallback rule for senior management — but the details are not identical. For a family with companies in both areas this means: for each entity it must be clear which regime applies, which register is responsible and which threshold is used. A single threshold for the whole family is misleading; our article on UBO determination across jurisdictions explains why.
What to prepare now
- Structure inventory: which entities, accounts and trusts of a family sit in the EU or Liechtenstein, and which counterparties are based there?
- Owners per jurisdiction: record the beneficial owners of each entity under the law applying there, with the derivation.
- Documentation: do source of wealth, risk classification and screening results withstand a more uniform, stricter standard?
- Counterparties: ask EU banks which documents they will require from when, rather than waiting for the questionnaire.
- Processes: link structural changes to every affected register and counterparty, not only the Swiss register.
Registers and access
A side issue with consequences: following the Court of Justice judgment of November 2022, general public access to EU registers ended; access requires a legitimate interest. The new package governs that access uniformly. For obliged entities using registers in their due diligence, access becomes clearer; for the public it remains restricted. In Switzerland the register was non-public from the start.
Perspective
The AMLR does not change everything for a well-documented Swiss structure. It does raise the likelihood that gaps will be noticed — by an EU bank, in a due diligence, in a transaction. Recording the structure cleanly once and assessing beneficial owners per jurisdiction prepares you for both regimes. In FLIORE, each beneficial owner is assessed against the rules of their own jurisdiction, from the EU threshold to the Swiss regime. In-depth guides on the AMLR and on thresholds by country are in the FLIORE knowledge hub.