Follow-up measures to the FATF country review (2017)

The Financial Action Task Force (FATF) conducted its fourth country review of Switzerland from 2015 to 2016. It examines a country’s anti-money laundering and counter-terrorist financing system, with a particular focus on financial market regulation. As a result of shortcomings identified during the review, Switzerland is now in the enhanced follow-up process, in spite of achieving a good overall result. On 28 June 2017, the Federal Council communicated guidelines for the follow-up work to the FATF country evaluation and instructed the Federal Department of Finance (FDF) to prepare a consultation draft. The Federal Council also highlighted the importance of amending the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA), the Agreement on the Swiss Banks’ Code of Conduct with regard to the Exercise of Due Diligence (CDB) and the regulation of self-regulatory organisations. As part of this package of measures, FINMA discussed possible implementation approaches with representatives of the financial centre and held a public consultation on the partial revision of AMLO-FINMA in September and October 2017. AMLO-FINMA is due to be finalised in summer 2018, coming into force in 2020, although material decisions pertaining to the verification of the beneficial owner and periodic updating of client information will have to be regulated at statutory level in accordance with the outcome of the consultation.


The country report also recommends the implementation of measures for improving the effectiveness of supervision by FINMA and SROs with respect to combating money laundering. FINMA responded by increasing its supervision of AMLA reporting systems. It is also working towards aligning the SROs’ approaches to supervision. Switzerland must report annually to the FATF as part of the enhanced follow-up. Switzerland’s follow-up work is coordinated by the State Secretariat for International Finance (SIF).



(From the Annual Report 2017)