SWITZERLAND Law and Practice Contributed by: Bruno Ledrappier and Camille Vuillemin-Loup, Charles Russell Speechlys Switzerland
7. Enforcement Priorities and Case Law Developments 7.1 Enforcement Priorities Switzerland’s current enforcement priorities in finan - cial crime reflect a sustained focus on AML, corrup - tion, fraud and sanctions compliance, driven by Swit - zerland’s role as a major international financial centre and the heightened expectations of the Financial Action Task Force (FATF). AML enforcement remains the foremost priority, par - ticularly those involving foreign predicate offences and cross-border fund flows. FINMA continues to pursue enforcement actions against banks and financial insti - tutions for violations of due diligence and reporting obligations under the AMLA. In 2024 alone, FINMA conducted 733 investigations and concluded 38 enforcement proceedings against companies and individuals. Notable actions included findings of seri - ous AML breaches at multiple banks, with remedies ranging from disgorgement of unlawfully obtained profits to restrictions on onboarding high-risk clients. The MBaer case in early 2026 – where FINMA with - drew the bank’s licence and ordered liquidation after finding “serious, systematic shortcomings” in AML and sanctions compliance – demonstrates the regu - lator’s willingness to take the most severe measures available. A major reform of Switzerland’s AML framework is underway. In September 2025, Parliament adopted the Federal Act on the Transparency of Legal Enti - ties and the Identification of Beneficial Owners (LETA), establishing a central federal Transparency Regis - ter for beneficial ownership information, expected to enter into force in the second half of 2026. This register applies to most Swiss legal entities – includ - ing corporations, limited liability companies, and co- operatives – as well as foreign entities with a Swiss branch, effective administration, or Swiss real estate holdings. The reform also extends AML due diligence obligations to legal advisors involved in activities such as the formation or structuring of legal entities. These measures are designed to address deficiencies identi - fied in Switzerland’s 2016 FATF mutual evaluation and to prepare for the next FATF evaluation scheduled for 2027.
The OAG continues to prioritise international corrup - tion and bribery cases. The long-running Operation Lava Jato investigations remain active, with over CHF365 million repaid to Brazilian authorities. In January 2025, the Federal Criminal Court achieved a landmark conviction of a multinational commodi - ties trading company for failing to prevent bribery of a foreign public official – the first such prosecution of a multinational in Switzerland. The OAG has also formed an international prosecutorial alliance with British and French authorities to enhance cross-border anti-cor - ruption co-operation. The growing importance of digital assets and crypto- related financial services has led to increased scrutiny of crypto-asset service providers for compliance with anti-money laundering obligations. Additionally, sanctions compliance has grown in prominence, particularly in the context of Russia-relat - ed measures. FINMA continues to pursue individual accountability, including industry bans of up to five years for bankers involved in compliance failures, and has opened proceedings against individuals in sev - eral high-profile cases. The OAG reported significant outcomes in 2025 in cybercrime, money laundering and fraud, including convictions for hacking and bank- related fraud schemes. Overall, authorities are trend - ing towards higher fines, longer custodial sentences and more assertive enforcement across all categories of business crime. 7.2 Recent Case Law and Latest Developments Switzerland has undertaken several significant legisla - tive and reform initiatives in financial crime. The revi - sion of the AMLA, which has been under discussion for several years, and is expected to enter into force in the second half of 2026, aims to extend AML obliga - tions to certain non-financial sector activities, includ - ing the real estate sector and the advisory services of lawyers. The proposed amendments also seek to strengthen beneficial ownership transparency require - ments. The reform process has generated consider - able debate within the legal profession, particularly regarding the balance between transparency objec - tives and professional secrecy.
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