Switzerland's Anti-Money Laundering Regulations: A 2025 Guide

Switzerland has long been known as a global financial hub, attracting individuals and businesses from around the world. While its banking sector offers unparalleled discretion and security, it has also faced scrutiny for its historical role in facilitating financial secrecy. In response to international pressure and evolving financial crime risks, Switzerland has continuously strengthened its Anti-Money Laundering (AML) regulations. As of 2025, Swiss AML laws are more stringent than ever, with increased enforcement actions and severe penalties for non-compliance.

This guide explores Switzerland’s current AML framework, key regulatory authorities, recent developments, compliance obligations for financial institutions, and notable enforcement actions, including the recent penalties imposed on JP Morgan and Morgan Stanley.

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Overview of Switzerland’s AML Framework

Switzerland's approach to combating money laundering is grounded in both national legislation and international commitments. The core framework includes:

• Anti-Money Laundering Act (AMLA) – Establishes the fundamental obligations for financial institutions and other regulated entities.
• Financial Market Supervision Act (FINMASA) – Grants enforcement authority to the Swiss Financial Market Supervisory Authority (FINMA).
• Swiss Criminal Code (SCC) – Criminalises money laundering activities and provides legal mechanisms for prosecution.
• Ordinance on Combating Money Laundering and Terrorist Financing in the Financial Sector (AMLO-FINMA) – Sets out detailed requirements for financial institutions regarding customer due diligence and transaction monitoring.
• Swiss Financial Intelligence Unit (MROS) – Central authority responsible for receiving and analyzing suspicious transaction reports.

Switzerland has also aligned its AML framework with international standards set by the Financial Action Task Force (FATF) and participates in cross-border cooperation to combat financial crime.

Key Regulatory Authorities in Switzerland’s Anti-Money Laundering Framework

Switzerland's anti-money laundering (AML) framework is enforced by a network of regulatory bodies and law enforcement agencies, each playing a critical role in monitoring, investigating, and prosecuting financial crimes. These authorities ensure compliance with the Swiss Anti-Money Laundering Act (AMLA) and international AML standards, including those set by the Financial Action Task Force (FATF). Below are the primary institutions responsible for AML enforcement in Switzerland:

1. FINMA (Swiss Financial Market Supervisory Authority)

The Swiss Financial Market Supervisory Authority (FINMA) is the primary regulatory body overseeing financial institutions in Switzerland. It supervises banks, insurance companies, asset managers, securities firms, and other financial intermediaries to ensure they comply with AML regulations and prevent illicit financial activities.

Key Responsibilities of FINMA:

• Supervision and Compliance Oversight: Ensuring that regulated entities implement robust AML policies, conduct due diligence on customers, and report suspicious activities.
• Regulatory Enforcement: FINMA has the power to conduct audits, issue warnings, and require corrective measures if an institution is found non-compliant with AML laws.
• Administrative Sanctions: FINMA can impose fines, suspend or revoke operating licenses, and, in severe cases, liquidate firms found guilty of AML violations.
• Collaboration with International Regulators: As part of global AML efforts, FINMA cooperates with foreign regulators and financial crime agencies to track and prevent cross-border money laundering schemes.
• Public Enforcement Actions: FINMA regularly publishes enforcement actions against financial institutions that fail to meet AML obligations, serving as a deterrent to others in the industry.

Given the strict stance Switzerland takes on AML compliance, FINMA has not hesitated to issue heavy penalties against banks and financial firms that fail to uphold their legal responsibilities. Notably, FINMA can restrict an institution's ability to operate in the financial market if serious lapses in compliance are identified.

2. Money Laundering Reporting Office Switzerland (MROS)

The Money Laundering Reporting Office Switzerland (MROS) operates as Switzerland’s Financial Intelligence Unit (FIU) and is a division of the Federal Office of Police. It is responsible for receiving, analysing, and disseminating Suspicious Transaction Reports (STRs) to law enforcement authorities.

Functions of MROS:

• Suspicious Transaction Reports (STRs): MROS is the central body that collects and assesses reports from banks, financial institutions, and other regulated entities regarding potentially illicit transactions.
• Data Analysis & Risk Assessment: MROS processes reported cases using advanced financial intelligence tools to identify patterns of money laundering and financial crime.
• International Cooperation: MROS works closely with other financial intelligence units worldwide, sharing information and assisting with cross-border money laundering investigations.
• Liaison with Law Enforcement: After analysing STRs, MROS refers cases with strong indications of criminal activity to the Office of the Attorney General (OAG) or other prosecutorial bodies for further investigation.

MROS has seen a significant increase in STRs over the past years, reflecting both greater vigilance within financial institutions and an increasing sophistication in money laundering techniques.

3. Office of the Attorney General of Switzerland (OAG)

The Office of the Attorney General of Switzerland (OAG) is responsible for leading criminal investigations and prosecutions related to money laundering, terrorist financing, and other financial crimes. It plays a crucial role in bringing financial offenders to justice.

OAG’s Role in AML Enforcement:

• Criminal Investigations: The OAG initiates and directs money laundering investigations in collaboration with law enforcement agencies and international bodies.
• Prosecution of Offenders: The OAG prosecutes individuals and entities found guilty of engaging in or facilitating money laundering activities.
• Asset Seizure and Confiscation: The OAG has the authority to seize and confiscate assets linked to money laundering schemes, ensuring illicit funds do not remain in circulation.
• High-Profile AML Cases: The OAG has prosecuted several high-profile money laundering cases, demonstrating Switzerland’s commitment to financial integrity.

4. Cantonal and Federal Courts

Swiss courts, at both the cantonal and federal levels, play a key role in adjudicating money laundering offenses and imposing legal penalties on offenders.

Key Responsibilities of Swiss Courts in AML Cases:

• Legal Proceedings: Cantonal courts handle initial trials for money laundering cases, while the Federal Criminal Court adjudicates high-stakes financial crime cases.
• Sentencing and Fines: Courts determine fines, imprisonment terms, and other penalties for individuals and entities convicted of money laundering.
• Appeals and Legal Precedents: The Swiss Federal Supreme Court may hear appeals on major AML cases, shaping future interpretations of money laundering laws.

Switzerland's judiciary has imposed significant penalties on both individuals and corporations involved in money laundering schemes, reinforcing the country’s strict stance on financial crime.

Switzerland continues to enhance its AML regulations to align with international standards:

• Bilateral Agreement with Panama: In February 2024, Switzerland signed a bilateral agreement with Panama to strengthen cooperation in combating financial crimes, including money laundering. Notably, this treaty authorises the electronic transmission of mutual assistance requests, facilitating more efficient collaboration between the two countries.
• Proposed Transparency Measures: The Swiss National Council plans to introduce additional regulations in 2025, focusing on establishing a transparency register and enhancing the identification of beneficial owners. These measures aim to increase transparency in financial transactions and prevent the misuse of legal entities for illicit purposes

Recent Developments in Swiss AML Regulations (2025)

To address emerging threats and strengthen its financial system’s integrity, Switzerland has implemented several regulatory enhancements in recent years:

a) Stricter Beneficial Ownership Requirements

One of the most significant changes in 2025 is the introduction of enhanced beneficial ownership (BO) disclosure obligations. Companies, trusts, and other legal entities must now provide detailed information about their ultimate beneficial owners (UBOs), making it harder for illicit actors to conceal their identities behind complex structures.

b) Increased Transparency for Cryptocurrency Transactions

Given the rise of digital assets, Switzerland has extended AML regulations to cryptocurrency exchanges and wallet providers. These entities must now implement:

• Stronger customer due diligence (CDD) requirements
• Stricter monitoring of transactions exceeding CHF 1,000
• Immediate reporting of suspicious activities to MROS

c) Expansion of Due Diligence Obligations

Financial intermediaries are now subject to broader customer due diligence (CDD) measures, especially when dealing with politically exposed persons (PEPs), high-risk jurisdictions, and complex corporate structures. Institutions must conduct ongoing monitoring rather than relying on a one-time verification process.

d) Enhanced Penalties for Non-Compliance

Swiss authorities have ramped up fines and penalties for AML violations, sending a clear message that financial institutions must adhere strictly to regulations. This is evidenced by the recent high-profile enforcement actions discussed below.

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AML Compliance Obligations for Financial Institutions

Financial institutions operating in Switzerland must implement a robust compliance framework to prevent money laundering. Key requirements include:

Customer Due Diligence (CDD) & Know Your Customer (KYC)

Financial institutions must verify customer identities, assess their risk profiles, and conduct ongoing due diligence. Enhanced due diligence (EDD) is required for high-risk clients, including:

• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions
• Entities with complex ownership structures

Suspicious Activity Reporting (SAR)

Under Swiss law, financial institutions must immediately report suspicious transactions to MROS. Delays or failures to report can result in heavy penalties and reputational damage.

Internal Controls & Risk Assessments

All financial institutions must establish:

• A dedicated AML compliance officer
• Regular staff training programs
• Automated transaction monitoring systems
• Independent internal audits to assess AML effectiveness

Record-Keeping Requirements

Institutions must retain client records, transaction histories, and due diligence reports for at least ten years, ensuring transparency and accountability.

High-Profile Enforcement Action: 2025

Swiss regulators have demonstrated zero tolerance for AML non-compliance, imposing significant penalties on financial institutions. One recent example highlight this trend:

Morgan Stanley Fined CHF 1 Million

In February 2025, the Office of the Attorney General of Switzerland (OAG) fined Morgan Stanley CHF 1 million after finding that one of its client advisors engaged in qualified money laundering linked to bribery in Greece. The case highlighted the importance of internal oversight, as the bank failed to prevent illicit transactions despite existing regulations.

These cases demonstrate that Swiss authorities are willing to hold major financial institutions accountable and impose substantial penalties for AML failures.

Implications for Financial Institutions

Given Switzerland’s rigorous AML enforcement, financial institutions must:

• Strengthen internal controls to detect and prevent suspicious transactions.
• Enhance staff training on AML compliance and emerging financial crime risks.
• Utilize advanced AI-driven monitoring tools to improve transaction surveillance.
• Regularly update policies to reflect evolving AML regulations and international standards.

Non-compliance not only results in hefty fines but also damages institutional reputation and may lead to licensing restrictions.

Conclusion: Switzerland’s Anti-Money Laundering Regulations 2025

Switzerland’s AML enforcement framework is robust and multi-layered, involving FINMA, MROS, the OAG, and Swiss courts. These institutions work together to monitor financial transactions, investigate suspicious activities, and penalise those who attempt to exploit the Swiss financial system for illicit purposes. Recent high-profile cases, such as the Morgan Stanley fine and other banking sector penalties, highlight that Swiss authorities are willing to impose severe consequences on institutions failing to uphold AML regulations. With the increasing complexity of financial crime, Switzerland remains committed to strengthening its AML laws and enforcement mechanisms in 2025 and beyond.

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