Fiduciaries
Anyone who professionally sets up or manages companies or provides domicile addresses has been fully subject to the AMLA since October.
1 October 2026 – AMLA revision & TJPG in force
Have you been subject to training obligations since October?
The 2026 AMLA revision subjects fiduciaries, lawyers, notaries, real estate agents and domicile providers to the full AML due diligence obligations for the first time – including SRO membership and mandatory training for all employees.
Affected professions
Who is covered by the new AMLA obligations?
Real estate agents
Anyone who professionally assists in the purchase or sale of real estate – including share deals – is now subject to the full due diligence obligations.
Lawyers & notaries
Where the activity involves structuring or advisory work (not purely litigation), the AMLA applies. Pure court representation remains exempt.
Domicile providers
Firms that provide registered addresses, management mandates or board mandates are directly affected.
Structuring advisors
M&A advisors and succession advisors who structure transactions independently – now subject to the AMLA.
Trust service providers
Trustees and settlor advisors with a connection to Switzerland have been fully subject to the AMLA since October, including SRO membership.
Important: All newly covered firms must join a recognised SRO (VQF, PolyReg, ARIF, SRO-Treuhand|Suisse, etc.) and provide evidence that their employees are trained. The SRO checks this as part of its periodic audit.
Source: State Secretariat for International Finance SIF · HSLU Economic Crime Blog.
The new legal situation
What has changed since 1 October
SRO membership becomes mandatory
Newly covered advisors must join a FINMA-recognised self-regulatory organisation. Without an SRO, there is no lawful activity. Deadline: within 6 months of entry into force.
Full due diligence obligations
KYC, identification of the beneficial owner, risk-based clarifications and the duty to report to MROS now also apply to advisory professions.
Training & internal directives
As part of its audit, the SRO expects evidence that all client-facing employees are regularly trained in AMLA fundamentals – as well as written internal directives.
Transparency register (TJPG)
The new Federal Act on the Transparency of Legal Entities also entered into force on 1 October 2026. Financial intermediaries subject to the AMLA get read access and must report discrepancies.
The solution
AMLA training for newly covered financial intermediaries
1
Module 1
Introduction to Anti-Money Laundering
A solid introduction to the fundamentals of combating money laundering. Learn the legal framework and the key concepts that are essential for day-to-day practice in the Swiss financial sector.
In this module, you'll learn:
- Fundamentals of money laundering in Switzerland
- Legal framework (AMLA)
- Stages of money laundering
- Practical case studies from Switzerland
2
Module 2
Identification of the Contracting Party
Learn how to identify contracting parties correctly and in a legally sound manner. From document verification to ongoing monitoring – all key aspects of customer identification under Art. 3 AMLA.
In this module, you'll learn:
- Identification duty under Art. 3 AMLA (Know Your Customer)
- Source of Wealth (SoW) vs. Source of Funds (SoF)
- Accepted documents
- Face-to-face vs. non-face-to-face identification
3
Module 3
Identification of the Beneficial Owner
Explore the complex world of beneficial ownership. Learn how to identify and document the actual controlling persons – a key element in the fight against money laundering.
In this module, you'll learn:
- Establishing the beneficial owner of natural persons and legal entities
- The 25% threshold and how to apply it
- Forms A, T, I and S (different legal structures)
- Re-identification in case of doubt
4
Module 4
Enhanced Due Diligence
Deepen your understanding of higher risks in banking. From PEPs to complex structures – understand when additional clarifications are required and how to carry them out.
In this module, you'll learn:
- Politically exposed persons (PEPs): criteria and categories
- Enhanced due diligence and annual review
- Higher-risk business relationships and transactions
- Plausibility checks: origin, purpose and background of payments
5
Module 5
Documentation Obligations
Learn the essential requirements for legally compliant documentation. Find out how to document your clarifications and decisions in a traceable, FINMA-compliant way.
In this module, you'll learn:
- Creating, organising and retaining documents
- 10-year retention obligation under the AMLA
- Transparency for FINMA audits (zero tolerance)
- Accessibility and labelling for third parties
6
Module 6
Digital Assets
Dive into the world of digital assets. Find out which particular challenges cryptocurrencies and other digital assets pose for anti-money laundering.
In this module, you'll learn:
- Fiat money vs. cryptocurrencies (Bitcoin, Ethereum)
- Regulated vs. unregulated exchanges
- Coin mixers and obfuscation methods
- Risk assessment for crypto transactions
It’s that simple
Compliant in 3 steps.
No IT project. No effort.
Your employees can start training within 8 hours.
Step 1
1. Book a demo (optional)
15-minute call: we show you the platform live, clarify the number of users and the timeline – and you see exactly what the reporting looks like.
Choose a time slotStep 2
2. Activate the training
Send your employee list (Excel is fine) to info@finregswiss.ch. We set up all accounts, activate monitoring and reminders and send out the login details. Everything is live within 8 hours.
Download the Excel templateStep 3
3. Sit back and relax
Your employees learn independently. The system sends automatic reminders and we send you the reports. You are audit-ready at all times. Done.
Pricing
Transparent. No surprises.
You are not just paying for training. Always included: AML e-learning, FINMA- or SRO-specific content, automatic reminders, monitoring, certificates, audit trail, audit report, regulatory updates and setup within 8 hours.
Price calculator
Team: 10 employees
Compliance boutiques, small asset managers, trustees
Annual priceCHF 4'900 / yeartiered pricing, no jumps
CHF 490per employee / year
Included
- Setup & onboarding (8h)
- 6 modules DE/EN, continuously updated
- Compliance reporting tool
- Audit trail & evidence
- Monitoring & reminder system
- TJPG/transparency register update
- Certificates (per employee)
No demo needed: send your employee list and go live within 8 hours. Invoiced at onboarding, no automatic renewal.
FAQ
Answers to the key questions
Am I really affected as a fiduciary if I do not manage any assets?
Yes – if you set up or manage companies or provide domicile addresses. The 2026 AMLA revision covers advisory activities without power of disposal over assets for the first time, provided you are involved in structuring activities. Legal basis: Art. 2 para. 3bis of the revised AMLA.
How long do I have to join an SRO?
Following the entry into force on 1 October 2026, you have 6 months to submit an application to an SRO. As the admission procedure itself takes 4–8 weeks and internal directives must be in place beforehand, you should start now.
Is this training sufficient as evidence for the SRO?
The training covers all legally required topics and issues a personalised certificate as well as a complete audit trail – name, email, completion date and test result per module. This evidence is suitable for the SRO audit. FinReg Swiss training records have already been accepted as evidence in a VQF audit.
How does this differ from the bank training?
The SRO version refers to the AMLA and the regulations of your SRO (VQF, PolyReg, ARIF, etc.) – not to the CDB 20, which applies exclusively to banks. All core topics (due diligence, KYC, beneficial owners, MROS) are identical.
Is the transparency register (TJPG) covered?
Yes. Module 3 contains up-to-date content on the new transparency register (TJPG), which also entered into force on 1 October 2026. The content was updated in July 2026.
Not the right segment?
→ Are you FINMA-regulated? FINMA solution→ Do you second or place compliance staff? Staffing solution
What does SRO membership mean in practice?
You must become a member of a FINMA-recognised self-regulatory organisation (e.g. VQF, PolyReg, ARIF, SRO-Treuhand|Suisse). The SRO periodically checks whether you comply with your AMLA due diligence obligations – including internal directives, KYC processes and evidence of training. Once a complete application has been submitted, the admission procedure takes 4–8 weeks.
