SWITZERLAND Trends and Developments Contributed by: Jean-Marc Carnicé, Canonica Valticos Carnicé & Associés
to materialise in practice. Notably, the Swiss Federal Police’s (FEDPOL) 2024 Annual Report reveals – in the context of AML – that the number of reports submitted to the MROS has doubled between 2022 and 2024. This sharp increase underscores how the legal pressure placed on financial intermediaries is translating into more cautious reporting behaviour. While this may enhance detection capabilities, it also raises concerns about the risk of over-reporting and the potential reduction in efficiency within the system. On the legislative front, the 2024 dispatch reflects a strategic move towards enhanced transparen - cy, greater accountability, and stronger alignment with international standards. Measures such as the creation of a beneficial ownership register and the extension of due diligence obligations to high-risk advisory activities mark a significant deepening of Switzerland’s AML regime. These reforms address key vulnerabilities, particularly in the context of complex cross-border schemes where legal entities and professional services are used to obscure beneficial ownership and asset flows.
While these developments enhance Switzer - land’s ability to detect and deter financial crime, they also highlight an evolving paradigm where financial intermediaries are increasingly treated as frontline enforcers. This trend raises legitimate questions about legal certainty, proportionality, and the extent to which enforcement duties can be shifted to private actors in the fight against money laundering. The author acknowledges with thanks the valu - able contribution made to the present article by Me Léa Descombes, junior associate at Canon- ica Valticos Carnicé & Associés.
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