# AMLR Art. 20 — CDD measures > GwG Art. 8b has been in force since 1 October 2026. AMLR Art. 20 applies from 10 July 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]] - **Swiss provisions:** [[GwG Art. 3 - Verification of the identity of|GwG Art. 3]], [[GwG Art. 4 - Establishing the beneficial owner|GwG Art. 4]], [[GwG Art. 5 - Repetition of identification - re-establishing|GwG Art. 5]], [[GwG Art. 6 - Special due diligence obligations (clarification|GwG Art. 6]], [[GwG Art. 7 - Duty to keep records|GwG Art. 7]], [[GwG Art. 7a - Assets of low value (de|GwG Art. 7a]], [[GwG Art. 8b - Adviser CDD- identify client, establish|GwG Art. 8b]], [[GwV-FINMA Art. 44 - Required information|GwV-FINMA Art. 44]], [[GwV-FINMA Art. 45 - Natural persons and sole proprietors|GwV-FINMA Art. 45]], [[GwV-FINMA Art. 46 - Simple partnerships|GwV-FINMA Art. 46]], [[GwV-FINMA Art. 47 - Legal entities, partnerships and authorities|GwV-FINMA Art. 47]], [[GwV-FINMA Art. 48 - Form and handling of documents|GwV-FINMA Art. 48]], [[GwV-FINMA Art. 49 - Certification of authenticity|GwV-FINMA Art. 49]], [[GwV-FINMA Art. 50 - Waiver of certification and missing|GwV-FINMA Art. 50]], [[GwV-FINMA Art. 51 - Cash transactions|GwV-FINMA Art. 51]], [[GwV-FINMA Art. 51a - Virtual currency transactions|GwV-FINMA Art. 51a]], [[GwV-FINMA Art. 52 - Money and value transfers|GwV-FINMA Art. 52]], [[GwV-FINMA Art. 53 - Well-known legal entities, partnerships, authorities|GwV-FINMA Art. 53]], [[GwV-FINMA Art. 55 - Failure to identify contracting party|GwV-FINMA Art. 55]], [[GwV-FINMA Art. 56 - Controlling person – principle|GwV-FINMA Art. 56]], [[GwV-FINMA Art. 57 - Controlling person – required information|GwV-FINMA Art. 57]], [[GwV-FINMA Art. 58 - Exemptions from establishing controlling persons|GwV-FINMA Art. 58]], [[GwV-FINMA Art. 59 - Beneficial owner – principle|GwV-FINMA Art. 59]], [[GwV-FINMA Art. 60 - Beneficial owner – required information|GwV-FINMA Art. 60]], [[GwV-FINMA Art. 61 - Cash transactions – beneficial owner|GwV-FINMA Art. 61]], [[GwV-FINMA Art. 62 - Money and value transfers –|GwV-FINMA Art. 62]], [[GwV-FINMA Art. 63 - Domiciliary companies|GwV-FINMA Art. 63]], [[GwV-FINMA Art. 64 - Groupings of persons, trusts, asset|GwV-FINMA Art. 64]], [[VSB 20]] - **Detailed citation:** GwG Art. 3-7; Art. 8b (advisers); GwV-FINMA Art. 44-64 ## What it requires AMLR Art. 20(1) lists the customer due diligence measures obliged entities must apply: identify and verify the customer and beneficial owner; understand the purpose and nature of the relationship; screen the customer and beneficial owner, and legal-entity control above 50%, against targeted financial sanctions; assess the customer's business or occupation; conduct ongoing monitoring; screen for politically-exposed-person status; identify persons acting on the customer's behalf or benefiting from a transaction; and verify any representative's authority. Extent is risk-based (Art. 20(2)); entities must be able to demonstrate this to supervisors (Art. 20(4)). ## Swiss position GwG assembles the same package across several articles: Art. 3 (identify the contracting party), Art. 4 (establish the beneficial owner), Art. 5 (repeat identification or establishment on doubt), Art. 6 (special due diligence - purpose and background, risk-based scrutiny, with foreign PEPs always high-risk and domestic/international-organisation PEPs high-risk only alongside a further factor), and Art. 7 (documentation), with a de-minimis carve-out for low-value relationships (Art. 7a). Advisers instead follow the narrower Art. 8b set - see [[The adviser regime (2025 GwG revision)]]. GwV-FINMA Art. 44-64 supply identification documents, thresholds and beneficial-owner-declaration content for the institutions Title 5 covers; [[Scope note — GwV-FINMA Title 5 vs VSB 20]] applies. ## Key divergences AMLR Art. 20(1)(f) requires ongoing monitoring from every obliged entity; GwG delivers it through the general risk-based duty in Art. 6, but Art. 8b lists no monitoring duty for advisers, so the duty is genuinely narrower on the Swiss side once advisers are compared. Thresholds differ: GwV-FINMA Art. 51 sets identification at CHF 5,000 for currency exchange and CHF 15,000 for other cash transactions, Art. 51a at CHF 1,000 for virtual-currency transactions, and Art. 61 requires the beneficial-owner declaration from CHF 15,000; AMLR Art. 19 uses EUR 10,000 for occasional transactions, EUR 3,000 for cash (at least identification), and EUR 1,000 for fund transfers and for crypto-asset service providers. The AMLR's single beneficial-owner concept is also split in Swiss law between the controlling person (GwV-FINMA Art. 56-58) and the person economically entitled to the assets (Art. 59-64); see [[The Swiss beneficial-owner split]]. ## Effective dates GwG Art. 8b has been in force since 1 October 2026. AMLR Art. 20 applies from 10 July 2027. See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[VSB 20 Art. 4 - Identifying the contracting partner|VSB 20 Art. 4]] — VSB Art. 4 Abs. 1 obliges banks to identify the contracting partner on opening a relationship, the first of the measures listed in AMLR Art. 20(1) (point (a)); verification of identity is regulated in VSB Art. 9–12. *(direct)* - [[VSB 20 Art. 15 - Verifying persons opening relationships|VSB 20 Art. 15]] — VSB Art. 15 requires banks to verify the identity of the natural persons opening a legal entity's or partnership's relationship and, for legal entities, to take note of and document their signing-authority rules; AMLR Art. 20(1)(i) applies to any person purporting to act for the customer and requires verifying that they are authorised. *(related)* - [[VSB 20 Art. 27 - Establishing the beneficial owner|VSB 20 Art. 27]] — VSB Art. 27 requires a declaration of who is beneficially entitled to the assets (natural persons as a rule), the Swiss concept closest to AMLR Art. 20(1)(h) (persons on whose behalf the customer acts); it does not itself require verifying their identity as AMLR Art. 20(1)(b), (h) do, and ownership/control of legal entities is covered separately by VSB Art. 20. See The Swiss beneficial-owner split. *(related)* - [[VSB 20 Art. 20 - Establishing the controlling persons|VSB 20 Art. 20]] — VSB Art. 20 covers one limb of AMLR's beneficial-owner concept: controlling persons (25%+ votes or capital, other control) of operating legal entities. See The Swiss beneficial-owner split. *(related)* - [[GwV-FINMA Art. 20 - Monitoring business relationships and transactions|GwV-FINMA Art. 20]] — GwV-FINMA Art. 20 Abs. 1 requires effective monitoring of relationships and transactions, framed as ensuring that increased risks are identified; it corresponds to the ongoing-monitoring element in AMLR Art. 20(1)(f), detail at AMLR Art. 26. *(direct)* - [[GwV-FINMA Art. 22 - Documentation and retention of records|GwV-FINMA Art. 22]] — GwV-FINMA Art. 22 Abs. 1 requires documentation allowing FINMA and auditors to judge AML compliance, comparable to AMLR's duty to demonstrate appropriateness of CDD measures to supervisors. *(related)* - [[GwV-FINMA Art. 15 - Additional clarifications for higher risks|GwV-FINMA Art. 15]] — GwV-FINMA Art. 15 Abs. 2 lists occupation or business activity and PEP status among clarifications, but only for increased-risk relationships or transactions, whereas AMLR Art. 20(1) applies to every customer. *(related)* - [[FATF R.12 - Politically exposed persons|FATF R.12 — Politically exposed persons]] — FATF R.12 requires systems to identify whether a customer or beneficial owner is a PEP (reasonable measures to determine status for domestic PEPs), extending to family members and close associates, as in AMLR Art. 20(1)(g). *(direct)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 20 — English text (EUR-Lex, CELEX 32024R1624) > **Article 20** > *Customer due diligence measures* > 1. For the purpose of conducting customer due diligence, obliged entities shall apply all of the following measures: > (a) identifying the customer and verifying the customer’s identity; > (b) identifying the beneficial owners and taking reasonable measures to verify their identity so that the obliged entity is satisfied that it knows who the beneficial owner is and that it understands the ownership and control structure of the customer; > (c) assessing and, as appropriate, obtaining information on and understanding the purpose and intended nature of the business relationship or the occasional transactions; > (d) verifying whether the customer or the beneficial owners are subject to targeted financial sanctions, and, in the case of a customer or party to a legal arrangement who is a legal entity, whether natural or legal persons subject to targeted financial sanctions control the legal entity or have more than 50 % of the proprietary rights of that legal entity or majority interest in it, whether individually or collectively; > (e) assessing and, as appropriate, obtaining information on the nature of the customers’ business, including, in the case of undertakings, whether they carry out activities, or of their employment or occupation; > (f) conducting ongoing monitoring of the business relationship including scrutiny of transactions undertaken throughout the course of the business relationship to ensure that the transactions being conducted are consistent with the obliged entity’s knowledge of the customer, the business and risk profile, including where necessary the source of funds; > (g) determining whether the customer, the beneficial owner of the customer and, where relevant, the person on whose behalf or for the benefit of whom a transaction or activity is being carried out is a politically exposed person, a family member or person known to be a close associate; > (h) where a transaction or activity is being conducted on behalf of or for the benefit of natural persons other than the customer, identifying and verifying the identity of those natural persons; > (i) verifying that any person purporting to act on behalf of the customer is so authorised and identify and verify their identity. > 2. Obliged entities shall determine the extent of the measures referred to in paragraph 1 on the basis of an individual analysis of the risks of money laundering and terrorist financing having regard to the specific characteristics of the client and of the business relationship or occasional transaction, and taking into account the business-wide risk assessment by the obliged entity pursuant to Article 10 and the money laundering and terrorist financing variables set out in Annex I as well as the risk factors set out in Annexes II and III. > Where obliged entities identify an increased risk of money laundering or terrorist financing they shall apply enhanced due diligence measures pursuant to Section 4 of this Chapter. Where situations of lower risk are identified, obliged entities may apply simplified due diligence measures pursuant to Section 3 of this Chapter. > 3. By 10 July 2026, AMLA shall issue guidelines on the risk variables and risk factors to be taken into account by obliged entities when entering into business relationships or carrying out occasional transactions. > 4. Obliged entities shall at all times be able to demonstrate to their supervisors that the measures taken are appropriate in view of the risks of money laundering and terrorist financing that have been identified. ## Sources - AMLR Art. 20 - CELEX 32024R1624 - GwG SR 955.0, Art. 3, 4, 5, 6, 7, 7a - GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 8b - GwV-FINMA SR 955.033.0, Art. 44-64