The Federal Council sets 1 October 2026 as the date for the entry into force of the amended Anti-Money Laundering Act and the new Transparency Act

On 26 September 2025, the Federal Parliament adopted the amendment to the Anti-Money Laundering Act (AMLA) and the new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), based on the Federal Council’s dispatch on strengthening the fight against money laundering. The Federal Council has now set the date for the entry into force of both acts, together with the associated implementing ordinances, as 1 October 2026; the sole exception being the provisions relating to public notaries, the implementation of which still requires amendments to cantonal legislation.

The TJPG establishes a central, non-public transparency register, which is maintained by the Federal Office of Justice. In particular, Swiss companies (AGs, GmbHs and cooperatives), foreign legal entities with their effective management or property holdings in Switzerland, and certain trustees are required to register their beneficial owners.

Upon entry into force on 1 October 2026, the transitional periods for the initial registration of beneficial owners in the new transparency register will begin to run. Companies should use the time remaining to review their ownership and control structures and compile the necessary information.

For many companies, the practical question now arises as to who qualifies as a beneficial owner and what internal processes need to be established to fulfil the reporting and updating obligations. Boards of directors and management teams should therefore begin preparing without delay. Breaches of the reporting and updating obligations may be subject to fines of up to CHF 500,000.

The amendment to the Anti-Money Laundering Act extends the scope of the act to cover certain high-risk advisory activities, notably those relating to property transactions and the formation, structuring and management of legal entities. In addition, new organisational obligations are being introduced under the Embargo Act to prevent breaches of international sanctions.

The amendments to the Anti-Money Laundering Act (GwG) and the Money Laundering and Terrorist Financing Prevention Act (TJPG) form a key part of the implementation of the Financial Action Task Force (FATF) international standards and are intended to strengthen Switzerland’s position ahead of the next country review in 2027/2028.

Revision of the Competition Act: Referendum period has expired; regulations are out for consultation

On 19 December 2025, Parliament passed the partial amendment to the Competition Act (KG). In particular, the reform modernises merger control by introducing the SIEC test (Significant Impediment to Effective Competition), facilitates the enforcement of competition law claims under civil law by broadening the range of persons entitled to bring proceedings, and improves the objection procedure. The amendment is not expected to come into force before early 2027.

Investment Review Act: Referendum deadline has passed; entry into force still uncertain

As reported in our last client newsletter, in December 2025 Parliament passed the Investment Screening Act (IPG), through which Switzerland has, for the first time, introduced a mechanism for scrutinising takeovers of domestic companies by foreign, state-controlled investors in sectors critical to national security.

The deadline for calling a referendum expired on 17 April 2026. The Federal Council must now draw up the implementing ordinance and establish the administrative structures required for implementation within the State Secretariat for Economic Affairs (SECO). Entry into force is still not expected before 2027.

Since the application of the new rules is limited to specific cases, no significant impact on M&A activity in Switzerland is expected. Nevertheless, disposals of shareholdings, joint ventures and cross-border M&A transactions involving potential foreign investors will need to be carefully reviewed going forward.

FINMA sets out its supervisory expectations in more detail

In the first half of 2026, the Swiss Financial Market Supervisory Authority FINMA published several supervisory notices on current risks in the financial sector. In Guidance 03/2026, it set out in more detail its expectations regarding the handling of complex, high-risk and illiquid products in personal wealth management. Furthermore, in Guidance 01/2026, it clarified the requirements for the custody of crypto-based assets, particularly with regard to their separability in the event of insolvency and their transfer to third-party custodians.

These publications highlight FINMA’s ongoing focus on governance, risk management and documentation at supervised institutions.