On 12 June 2026 the Swiss Federal Council decided to bring the revision of the Anti-Money Laundering Act (AMLA, in German GwG) and its ordinance into force together with the TJPG on 1 October 2026. The most important change for many law firms, fiduciaries and consultancies: certain advisory activities are now subject to the AMLA’s due diligence duties, even if the advisers never handle assets themselves.
Until now the AMLA was tied to financial intermediation: accepting, holding or helping to invest or transfer third-party assets brought you into scope. The revision broadens that approach. Now professional advice or support can also be covered when it relates to a concrete legal transaction carrying a heightened money laundering risk.
Which activities are covered
In its notes on the revision, FINMA gives as examples advisory activities in connection with real estate transactions and with the formation and establishment of non-operating legal entities. Industry overviews name lawyers and notaries, fiduciaries, asset managers and real estate agents as particularly affected professional groups, each depending on the specific activity. Coverage therefore depends not on the profession but on what is actually done.
Three features shape the assessment. First, the advice must be provided professionally. Second, there must be a concrete legal transaction — a specific deal, a specific formation, a specific restructuring — not merely general advice. Third, the advice or support must contribute to that transaction. Exempt, among other things, are legal and notarial activities in connection with court, criminal and administrative proceedings. For cantonal official notaries, entry into force is postponed because the cantons must first adapt their legislation.
What coverage means
Anyone falling under the new provisions must join a FINMA-recognised self-regulatory organisation and comply with the anti-money laundering due diligence duties. The SRO specifies the scope of those duties in its regulations, and compliance is checked by audit firms. At the core are the familiar obligations:
- identifying the contracting party and establishing the beneficial owner, for companies as part of KYB
- a risk classification under the risk-based approach, with enhanced due diligence for higher risks
- sanctions and PEP screening
- documentation allowing qualified third parties to form a judgement, retained for at least ten years
- internal directives, training and controls
- a defined way of handling suspicious cases, up to a suspicious activity report to MROS
Also new for advisers is access to the transparency register within their AMLA duties. It makes the determination easier for Swiss companies but does not replace it.
Deadlines
The due diligence duties have applied to new mandates since 1 October 2026. For joining an SRO, the transitional rules provide a short period ending in December 2026; the chosen SRO confirms the binding cut-off date and the documents for the application. FINMA-supervised entities and licence holders that were acting as advisers on 1 October 2026 must notify FINMA by 1 December 2026 via a form on its survey and application platform; they may continue to advise existing clients and accept new mandates.
Anyone who has not yet checked whether they are affected should do so in the coming weeks. Checking in December leaves hardly any time to choose an SRO, read its regulations and adapt your own processes.
The order of work
First, map your own activities: which mandates in the last twelve months concerned a concrete legal transaction, and of what kind? Second, assess coverage and record the result with reasons, even if negative. Third, if affected, choose an SRO and read its regulations before applying. Fourth, define a risk method and describe the processes for identification, determination, screening, documentation and suspicious cases. Fifth, train staff and set up filing so that an SRO audit finds sampled files without searching. The individual steps with verifiable criteria are in our checklist on AMLA coverage for advisers.
The most common misjudgements
The first misjudgement: we never touch money, so this does not affect us. That is precisely the assumption the revision removes. The second: we are lawyers, so we are exempt. Litigation work is exempt, not every legal activity; advising on setting up a structure can be covered. The third: forms are enough. An SRO does not check whether forms exist, but whether decisions are traceable.
The organisational opportunity
For many small law firms and fiduciaries, coverage is effort without direct return. But it forces something that makes sense anyway: clean mandate management with clear responsibilities, current client data and a traceable audit trail. Set that up once and you answer not only the SRO audit more easily, but also the questions of banks, auditors and successors. Tools like FLIORE are built for exactly this work: KYC, controls and evidence per mandate in one workflow.
At Innopulse we advise on digitising such processes, not on legal coverage. For whether a specific activity is covered, the chosen SRO or a specialised law firm is the right address. For how the duties then run efficiently day to day, talk to us in an initial conversation.