GwG — Swiss Anti-Money Laundering Act

The Federal Act on Combating Money Laundering and Terrorist Financing (GwG) constitutes the central legal framework for preventing and combating money laundering and terrorist financing in Switzerland. It entered into force on 1 April 1998 and has been revised several times, most comprehensively in 2021 to implement FATF recommendations.

• Due diligence obligations: Identification of contracting parties and beneficial owners
• Reporting obligations: Suspicious activity reports to MROS upon suspicion of money laundering
• Organizational obligations: Internal control systems, training, compliance structures
• SRO system: Affiliation with a recognized self-regulatory organization or direct FINMA supervision
• Documentation obligation: Retention of records for at least 10 years

The GwG was enacted in response to international developments: the Financial Action Task Force (FATF) was established in 1989 at the initiative of the G7 and issued 40 recommendations on combating money laundering. Switzerland, as a major financial center, faced particular pressure to implement international standards.

The GwG entered into force on 1 April 1998, for the first time creating a comprehensive framework covering all financial intermediaries. It was fundamentally revised in 2012 (introduction of terrorist financing offence) and 2021. The 2021 revision particularly increased transparency requirements for legal entities, tightened obligations for traders, and lowered the cash threshold.

The GwG applies to all financial intermediaries in Switzerland:

• Banks and securities dealers
• Fund management companies and asset managers of collective investment schemes
• Independent asset managers and trustees
• Life insurers (to the extent involving savings or investment components)
• Payment service providers and currency exchangers
• Casinos
• Traders (for cash payments over CHF 100,000)
• Lawyers and notaries (pursuant to GwG revision adopted Sept. 2025, expected to enter into force mid-2026)

• Identification obligation: Establishment of identity of contracting parties (natural and legal persons)
• Beneficial owner identification: Identification of economic owners (beneficial owner)
• Risk-based approach: Enhanced due diligence for elevated risks (PEPs, high-risk countries)
• Politically exposed persons (PEPs): Special monitoring obligations and senior management approval
• Reporting obligation upon suspicion: Immediate report to MROS
• Documentation: Retention of all records for at least 10 years
• Training obligation: Regular training of staff
• SRO affiliation: Mandatory membership in a recognized SRO or direct FINMA supervision

GwG implements international AML standards — connection to EU AML Package was missing.

"AMLA — Anti-Money Laundering Act" was classified under theme "Jurisdiktion". Correct is "AML-KYC". National laws and authorities are classified by subject matter, not as Jurisdiction. Country profiles are classified as Jurisdiction.

2 corrections:
- CH-GwG: Scope includes future law as current law (CHF 15,000, lawyers)
- CH-GwG: Multiple key_dates entries have wrong dates and wrong descriptions
1 update:
- GwG key_date 2023: 'Planned revision' has since been adopted