On 1 October 2026, Switzerland brought two new laws into force: the revised Anti-Money Laundering Act and the Federal Act on the Transparency of Legal Entities together create a central register of beneficial owners and bring a new group of advisers into the AML regime.

Switzerland is tightening its approach. The United States has gone the other way and removed beneficial ownership reporting for domestic companies. The EU sits somewhere between the two, with registers that can only be accessed by those who show a legitimate interest.

Three major financial centres are now moving in three different directions. For any firm operating across them, that creates a compliance problem, and more importantly, a people problem.

At Broadgate, we recruit compliance, financial crime and risk specialists across Switzerland, the UK, Ireland, Luxembourg and the US, so we see first-hand where these regimes collide and what that means for the teams firms need to build.

What's changed in Switzerland

A central transparency register. Legal entities must now report their beneficial owners to a new transparency register run by the Federal Office of Justice. Changes must be reported within 30 days, and existing entities have a short transitional period to register.

The register isn't public. Access is limited to designated authorities, supervisory bodies and self-regulatory organisations, and to financial intermediaries and others subject to AML rules, who can consult it to support their own due diligence.

Advisers come into scope. Lawyers, notaries and other advisers now carry AML due diligence obligations when they assist professionally with financial transactions linked to certain activities. These include buying or selling real estate, setting up or managing companies, foundations and trusts, organising funding for a company, and buying or selling a company. The provisions for public notary offices follow later, once the cantons have adapted their own legislation.

Real penalties. Serious breaches can lead to criminal fines of up to CHF 500,000, and entities that fail to comply risk the suspension of shareholder rights.

The Federal Council timed the changes so their effect can be assessed in the next Financial Action Task Force evaluation of Switzerland, scheduled for 2027 to 2028.

The US and the EU are heading elsewhere

United States. In March 2025, FinCEN issued an interim final rule exempting US companies and US persons from beneficial ownership reporting under the Corporate Transparency Act. It's since been made permanent. Only foreign entities registered to do business in the US now have to report.

European Union. In 2022, the Court of Justice of the EU ended general public access to beneficial ownership registers. The EU's new anti-money laundering framework replaces it with access based on legitimate interest, with journalists, civil society and academics working on financial crime presumed to qualify. Member states are implementing this at different speeds and in different ways.

Why divergence becomes a people problem

For a firm working in one market, a change in UBO rules is a policy update. For a firm working across Switzerland, the EU and the US, it changes how customer due diligence works in practice.

A Swiss wealth manager onboarding a US company can no longer expect beneficial ownership data to have been filed with US authorities. The same firm onboarding an EU entity faces access rules that vary by member state. A trust company or law firm that never needed an AML function may now need one built from the ground up.

None of this is solved by a new policy document alone. It needs people who understand how the regimes interact and who can turn that understanding into working controls, KYC processes, data standards and governance.

That's the real question for leadership teams. It's no longer only whether the firm is compliant. It's whether the firm has the people to put the new requirements into practice.

What this means for wealth managers and private banks

Wealth managers, private banks and family offices are among the firms most exposed to the new Swiss rules. Their clients often hold assets through companies, trusts and foundations across several jurisdictions, which is exactly where beneficial ownership is hardest to establish.

For these firms, the changes are likely to mean:

  • Reviewing existing client files against the new register and reporting requirements
  • Rethinking onboarding for clients with US or EU entities, where the beneficial ownership information available differs by jurisdiction
  • Strengthening first and second line teams, from KYC analysts to MLROs, with people who understand cross-border structures
  • Bringing in interim or project support for remediation while permanent teams are built

These are specialist hires in a tight market. Firms that plan early will have far more choice than those that wait for their next regulatory review.

Where we expect demand

Based on the changes above, we expect firms operating across these markets to need:

  • MLROs and Heads of Financial Crime with cross-border experience across Swiss, EU and US regimes
  • KYC and CDD specialists, including remediation leads to review existing client files against the new requirements
  • Regulatory change and project managers who can translate new rules into policies, controls and training
  • Compliance professionals for law firms, trust companies and corporate service providers building an AML function for the first time
  • Governance and data specialists to improve the quality and consistency of beneficial ownership data

The firms most affected are likely to include Swiss private banks and wealth managers, family offices and fiduciaries, private equity and asset managers, banks with cross-border client bases, FinTech and payments businesses, and the legal and corporate services firms now in scope.

Hiring leaders the regulator will approve

Many of these are senior roles that regulators scrutinise closely, and in the UK and Ireland they need regulatory approval. A strong CV isn't enough. Boards need evidence that a candidate has the competence, judgement and integrity for the role.

That's why our senior compliance and financial crime searches use the Broadgate Search Fit and Proper Framework™, our proprietary 12-step assessment methodology. It has an established track record of delivering regulatory approvals from the PRA, FCA and Central Bank of Ireland.

Our consultants run these searches alongside Adrian McCarthy, Senior Advisor to Broadgate and Trinnovo Group. Adrian's seen these appointments from the regulator's side, as a Governance and Risk Technical Specialist at the FSA and FCA and as a fintech supervisor at the Dubai Financial Services Authority. He's also been Group Customer Director at Lloyds Banking Group and a partner at a top-10 UK law firm, and today works with chairs, CEOs and boards as a board effectiveness reviewer and coach.

In practice, the framework means:

  • Agreeing up to eight key competencies with the board or employer before the search starts
  • 90 to 120 minute structured interviews with Broadgate experts, with optional psychometric testing
  • An independent report on each candidate, RAG-rated against those competencies, plus a ranked overview of the shortlist
  • Support through offer and the first six months in role

For a firm hiring an MLRO or Head of Financial Crime to lead its response to the new rules, this gives the board independent evidence behind the appointment.

Questions to ask your leadership team now

  • Which of our entities, services and client relationships fall within the new Swiss requirements?
  • Who in our team understands how the Swiss, EU and US approaches interact?
  • Are our KYC processes still built around a single regime?
  • Is this a permanent capability we need to build, or a project that needs interim expertise?
  • If a remediation or UBO data project starts tomorrow, do we have the people to run it?
  • How will we show the regulator that a new MLRO or Head of Financial Crime is fit and proper?

Building the team to put the new rules into practice

Broadgate helps financial and professional services firms build regulator-ready teams across Compliance, Financial Crime, Risk, Change and Governance. Because we recruit across Switzerland, the UK, Ireland, Luxembourg and the US, we can help you find people who understand how these regimes interact, not just how one of them works.

We can support you with:

  • Permanent leadership hires, from Heads of Financial Crime to MLROs
  • Fit and proper assessment of senior appointments, using our 12-step framework
  • Interim and project specialists for remediation, KYC review and UBO data work
  • Salary benchmarking, so you know what these roles cost before you start a search

To benchmark pay now, see our RegTech and Compliance Salary Guide for Switzerland, or read our view on five financial crime regulation changes UK firms should be preparing for in 2026.

If you're working out what the new rules mean for your team, talk to our Zug team or Adrian McCarthy for a confidential conversation about the hires you may need.

Sources

  • finews.ch, New Anti-Money Laundering and Transparency Rules to Take Effect in October
  • EY Switzerland, Switzerland AML reform and new transparency obligations
  • FinCEN, Beneficial Ownership Information (fincen.gov/BOI)
  • Transparency International, Countdown to new EU beneficial ownership rules