Revised AMLA: what changes for companies and their advisers in Switzerland?
Office Consultant Société Fiduciaire SA
Since 1 October 2026, Switzerland's Anti-Money Laundering Act (AMLA) also applies to certain advisers, including providers of registered addresses. For a company, that means a few details to hand over to its adviser and, in most cases, a filing with the new transparency register. These are federal rules: they apply in Geneva as everywhere else in Switzerland.
Which activities are covered?
Lawyers, notaries, fiduciaries, real estate agents: any of them can now be an "adviser" under the AMLA when they act professionally in one of these activities (Art. 2 para. 3bis and 3ter AMLA):
buying or selling real estate;
setting up or administering non-operating companies, setting up companies abroad, and certain transactions involving these structures;
domiciling a company for more than six months
Who carries out the checks?
The adviser. They identify the client and the beneficial owner, understand the purpose of the mandate (Art. 8b AMLA), keep records and report well-founded suspicions to MROS. They must join a self-regulatory organisation (SRO) recognised by FINMA (Art. 14 AMLA), and an audit firm checks compliance. Application deadline for those already in business: 1 December 2026. Put simply: no SRO, no mandate.
What information can you be asked for?
A commercial register extract, ID for the signatories, the beneficial owner's identity and a few words about your business or transaction. Where the risk is higher, for example a complex structure or a link to a high-risk country, the adviser will ask further questions. It is not mistrust: it is the law, and it applies to everyone.
A practical case
Léa sets up a consulting Sàrl (limited liability company) in Geneva and domiciles it with her fiduciary while she looks for offices. Setting up an operating company is not, in itself, a covered activity. Domiciliation is, once it exceeds six months. Before signing, Léa provides her ID, confirms that she is the beneficial owner and describes her business in three lines. That's it.
Domiciliation: an address alone is no longer enough
A Geneva address, a letterbox, a name on the door: for years, domiciling a company was that simple. At Office Consultant, domiciliation now runs within the AMLA framework, and we have turned that into an advantage.
A registered office that stays put. A provider without an SRO must stop domiciling. For your company, that would mean finding a new registered office and updating the commercial register, in a hurry.
Paperwork, not an interrogation. We ask for what the law requires, nothing more, then a simple periodic update.
An address, and a whole team. Mail, calls, accounting, tax, transparency register filing: one point of contact, a boutique fiduciary firm, and the discretion that comes with it.
Lawyer, notary or fiduciary: do you domicile client companies?
If you do so professionally and for more than six months, all of the above applies to you, SRO membership and external audit included, at your own expense. For a handful of mandates, it is rarely worth the effort. Refer these clients to us: you keep your client and your mandate, and we take on the domiciliation and its AML framework.
Box · Transparency register (LTPM)
Since 1 October 2026, most companies must report their beneficial owners to this federal register. Existing companies: between 31 December 2026 and 31 March 2027 depending on legal form and audit status, or by 30 September 2028 if all beneficial owners already appear in the commercial register. New companies: within one month. Filing is free on EasyGov.swiss (beware of sites that charge for it), and the register is not public.
Setting up a company, domiciliation, an existing structure: let's look at what the revision means for your project. Write to us, and we will get back to you personally.
Written and reviewed by Office Consultant · Updated 10 November 2026
Official sources (in French): SFI, révision de la LBA ; modification de la LBA du 26 septembre 2025 ; LBA (RS 955.0), art. 2 al. 3bis et 3ter, 7, 8b à 8d, 9 al. 1ter et 14 ; OBA (RS 955.01), art. 12f à 12g et dispositions transitoires ; LTPM (RS 955.3) ; registre de transparence.
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