{"id":236699,"date":"2026-10-09T09:00:00","date_gmt":"2026-10-09T07:00:00","guid":{"rendered":"https:\/\/www.rister.ch\/?p=236699"},"modified":"2026-10-09T11:24:08","modified_gmt":"2026-10-09T09:24:08","slug":"swiss-amla-domiciliation","status":"publish","type":"post","link":"https:\/\/www.rister.ch\/en\/post\/swiss-amla-domiciliation\/","title":{"rendered":"Swiss AMLA and domiciliation: domicile providers become advisers under the law"},"content":{"rendered":"
\n

Since 1 October 2026, the Swiss Anti-Money Laundering Act (AMLA) has applied to domiciliation. Anyone who, on a professional basis, provides a legal entity with an address or premises as its domicile or registered office for more than six months is deemed an \u201cadviser\u201d (Art. 2 para. 3ter AMLA). The provider must identify the client and the beneficial owner, keep records, train its staff, report suspicions to the Money Laundering Reporting Office Switzerland (MROS) and join a self-regulatory organisation (SRO). Domicile providers already operating on 1 October have until 1 December 2026 to act.<\/p>\n

This guide sets out the framework from the provider’s side and ends with an AMLA domiciliation checklist to work through before the deadline.<\/p>\n<\/div>\n

\n

Contents<\/h3>\n
    \n
  1. AMLA domiciliation: what changes on 1 October 2026<\/a><\/li>\n
  2. When a domicile provider becomes an adviser under the Swiss AMLA<\/a><\/li>\n
  3. The AMLA obligations of a domicile provider<\/a><\/li>\n
  4. SRO affiliation: the 1 December 2026 deadline<\/a><\/li>\n
  5. Corporate Service Providers already affiliated with an SRO<\/a><\/li>\n
  6. What the AMLA changes for the domiciled company<\/a><\/li>\n
  7. AMLA domiciliation checklist before 1 December 2026<\/a><\/li>\n
  8. Case study: a Geneva business centre and its 40 domiciled companies<\/a><\/li>\n<\/ol>\n<\/div>\n

    AMLA domiciliation: what changes on 1 October 2026<\/h2>\n

    Until 30 September 2026, providing a registered address did not bring a provider within the AMLA, as long as it neither managed its clients’ funds nor sat on their governing bodies. The Act knew only financial intermediaries and traders. It now has a third category, advisers (Art. 2 para. 1 let. c AMLA), and domiciliation is named in it.<\/p>\n

    The change comes from the amendment to the AMLA of 26 September 2025, published in the Official Compilation of Federal Legislation as AS 2026 322. Parliament passed it on the same day as the Federal Act on the Transparency of Legal Entities (LTPM). No referendum had been requested when the deadline expired on 15 January 2026, and the Federal Council set the entry into force for 1 October 2026.<\/p>\n

    \"Timeline
    The six dates of the reform. Sources: AS 2026 322, AS 2026 323 and AS 2026 364.<\/figcaption><\/figure>\n

    The provision that targets domiciliation fits in one sentence. Under Art. 2 para. 3ter AMLA, \u201clegal entities and natural persons who, on a professional basis, make an address or premises available to a legal entity as its domicile or registered office for a period exceeding six months are also deemed to be advisers\u201d (unofficial translation; the binding versions are German, French and Italian).<\/p>\n

    \n\n\n\n\n\n\n\n\n\n
    Point<\/th>\nUntil 30 September 2026<\/th>\nSince 1 October 2026<\/th>\n<\/tr>\n<\/thead>\n
    Status of the domicile provider<\/td>\nOutside the AMLA for domiciliation alone<\/td>\nAdviser (Art. 2 para. 3ter AMLA)<\/td>\n<\/tr>\n
    Due diligence<\/td>\nNone in respect of domiciliation<\/td>\nArt. 8b to 8d AMLA<\/td>\n<\/tr>\n
    Reporting to MROS<\/td>\nNone in respect of domiciliation<\/td>\nArt. 9 para. 1ter AMLA<\/td>\n<\/tr>\n
    Supervision<\/td>\nNone<\/td>\nAffiliation with an SRO (Art. 14 para. 1 AMLA)<\/td>\n<\/tr>\n
    Public disclosure<\/td>\nNone<\/td>\nPublic register kept by FINMA (Art. 18b AMLA)<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    Source: AMLA (SR 955.0), version in force since 1 October 2026, Fedlex.<\/p>\n<\/div>\n

    The general regime for financial intermediaries, with its internal organisation, AML officer and SRO audits, is a subject in its own right. Here, RISTER\u00ae deals with domiciliation only.<\/p>\n

    When a domicile provider becomes an adviser under the Swiss AMLA<\/h2>\n

    A domicile provider becomes an adviser when four conditions are met together: it acts on a professional basis, it provides an address or premises, the entity uses them as its domicile or registered office, and the arrangement lasts more than six months. If any one condition is missing, Art. 2 para. 3ter does not apply.<\/p>\n

    \"Decision
    The four questions that turn a domicile provider into an adviser under Art. 2 para. 3ter AMLA.<\/figcaption><\/figure>\n

    AMLA advisers: the four conditions of Art. 2 para. 3ter<\/h3>\n