# AMLR Art. 3 — Obliged entities > The GwG adviser categories (Art. 2 Abs. 1 Bst. c, 3bis-3ter, 4 Bst. f, 4bis-4ter, 5; Art. 2b) have been in force since 1 October 2026 (Abs. 3quater on public-law notaries, *Urkundspersonen*, is not yet in force); AMLR Art. 3 applies from 10 July 2027, except Art. 3(3)(n)-(o) (football agents and clubs), which applies from 10 July 2029. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.22 - DNFBPs - Customer due diligence|FATF R.22]], [[FATF R.23 - DNFBPs - Other measures|FATF R.23]], [[FATF R.15 - New technologies|FATF R.15]] - **Swiss provisions:** [[GwG Art. 2 - Scope of application (who is|GwG Art. 2]], [[GwG Art. 2a - Definitions (incl. politically exposed persons|GwG Art. 2a]], [[GwG Art. 2b - Material coordination where an activity|GwG Art. 2b]], [[GwG Art. 8a - Due diligence for dealers (cash|GwG Art. 8a]] - **Detailed citation:** GwG Art. 2 Abs. 1 Bst. c, 2 Abs. 3bis-3quater, 2 Abs. 4 Bst. f, 4bis, 4ter, 5 (rev.); Art. 2a Abs. 6; Art. 2b; Art. 8a ## What it requires AMLR Art. 3(3) lists the non-financial obliged entities: auditors, external accountants and tax advisers, and others (including lawyers) giving tax advice as principal activity (a); notaries, lawyers and other independent legal professionals on specified transactions (b); trust or company service providers (c); real estate professionals (d); dealers in precious metals/stones (e) and high-value goods (f); gambling providers (g); crowdfunding providers (h); cultural-goods traders (i)(j); mortgage/consumer credit intermediaries (k); investment migration operators (l); non-financial mixed activity holding companies (m); football agents (n); and professional football clubs for listed transaction types (o). ## Swiss position GwG Art. 2 Abs. 2 Bst. e-f brings casinos and operators of large-scale games (*Grossspiele*) within the financial-intermediary definition; Art. 2 Abs. 1 Bst. b with GwG Art. 8a covers goods dealers taking cash above CHF 100,000 (CHF 15,000 for precious metals and stones since 1 October 2026) - the closer match to AMLR's precious-metals and high-value-goods limbs. The 2025 revision adds Bst. c: advisers who professionally assist third parties with real-estate purchase/sale, formation and administration of non-operating legal entities, their contributions/distributions, and entity sales via a non-operating entity (Abs. 3bis), domiciliation services over six months (Abs. 3ter), and public-law notaries doing the same work (Abs. 3quater, not yet in force) - see [[The adviser regime (2025 GwG revision)]]. Litigation-related work by lawyers and notaries is excluded (Abs. 4 Bst. f); Abs. 4ter carves out family/inheritance transfers, sub-CHF-5-million transfers settled through a bank or other financial intermediary subject to the GwG, and other categories. GwG Art. 2b resolves overlap between financial-intermediary and adviser status in favour of the financial-intermediary rules. ## Key divergences Switzerland has no football-club or football-agent obliged-entity category matching AMLR Art. 3(3)(n)-(o); instead it reaches sport through the politically-exposed-person definition, treating senior officials of international sports federations - defined at GwG Art. 2a Abs. 5 as the IOC and the non-governmental organisations it recognises - as PEPs under Art. 2a Abs. 1 Bst. c. That is PEP due diligence on individuals, not an obliged-entity regime on clubs or agents, and it does not reach investor, sponsor or transfer transactions the way Art. 3(3)(o) does. See [[Effective-dates timeline]] for when each side's rule bites. The adviser category (Art. 2 Abs. 1 Bst. c, 3bis-3quater) tracks AMLR's real-estate and trust/company-service limbs (3(3)(b), (c)) only for listed transaction types, and carries de-minimis carve-outs (Abs. 4ter) with no direct AMLR Art. 3 counterpart. AMLR Art. 3(3)(a) (auditors, external accountants, tax advisers) has no dedicated obliged-entity category in GwG Art. 2. ## Effective dates The GwG adviser categories (Art. 2 Abs. 1 Bst. c, 3bis-3ter, 4 Bst. f, 4bis-4ter, 5; Art. 2b) have been in force since 1 October 2026 (Abs. 3quater on public-law notaries is not yet in force); AMLR Art. 3 applies from 10 July 2027, except Art. 3(3)(n)-(o) (football agents and clubs), which applies from 10 July 2029. 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. 1 - Scope|VSB 20 Art. 1]] — Both fix which institutions are bound; VSB 20 Art. 1 binds only banks and securities dealers with their Swiss-domiciled offices (not foreign branches, representations or subsidiaries), whereas AMLR Art. 3 also covers other financial institutions and non-financial obliged entities. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 3 — English text (EUR-Lex, CELEX 32024R1624) > **Article 3** > *Obliged entities* > The following entities are to be considered obliged entities for the purposes of this Regulation: > (1) credit institutions; > (2) financial institutions; > (3) the following natural or legal persons acting in the exercise of their professional activities: > (a) auditors, external accountants and tax advisors, and any other natural or legal person including independent legal professionals such as lawyers, that undertakes to provide, directly or by means of other persons to which that other person is related, material aid, assistance or advice on tax matters as principal business or professional activity; > (b) notaries, lawyers and other independent legal professionals, where they participate, whether by acting on behalf of and for their client in any financial or real estate transaction, or by assisting in the planning or carrying out of transactions for their client concerning any of the following: > (i) buying and selling of real property or business entities; > (ii) managing of client money, securities or other assets, including crypto-assets; > (iii) opening or management of bank, savings, securities or crypto-assets accounts; > (iv) organisation of contributions necessary for the creation, operation or management of companies; > (v) creation, setting up, operation or management of trusts, companies, foundations, or similar structures; > (c) trust or company service providers; > (d) estate agents and other real estate professionals to the extent they act as intermediaries in real estate transactions, including in relation to the letting of immovable property for transactions for which the monthly rent amounts to at least EUR 10 000 or the equivalent in national currency, irrespective of the means of payment; > (e) persons trading, as a regular or principal professional activity, in precious metals and stones; > (f) persons trading, as a regular or principal professional activity, in high-value goods; > (g) providers of gambling services; > (h) crowdfunding service providers and crowdfunding intermediaries; > (i) persons trading or acting as intermediaries in the trade of cultural goods, including when this is carried out by art galleries and auction houses, where the value of the transaction or linked transactions amounts to at least EUR 10 000 or the equivalent in national currency; > (j) persons storing, trading or acting as intermediaries in the trade of cultural goods and high-value goods, when this is carried out within free zones and customs warehouses, where the value of the transaction or linked transactions amounts to at least EUR 10 000 or the equivalent in national currency; > (k) credit intermediaries for mortgage and consumer credits, other than credit institutions and financial institutions, with the exception of the credit intermediaries carrying out activities under the responsibility of one or more creditors or credit intermediaries; > (l) investment migration operators permitted to represent or offer intermediation services to third-country nationals seeking to obtain residence rights in a Member State in exchange for any kind of investment, including capital transfers, purchase or renting of property, investment in government bonds, investment in corporate entities, donation or endowment of an activity to the public good and contributions to the state budget; > (m) non-financial mixed activity holding companies; > (n) football agents; > (o) professional football clubs in respect of the following transactions: > (i) transactions with an investor; > (ii) transactions with a sponsor; > (iii) transactions with football agents or other intermediaries; > (iv) transactions for the purpose of a football player’s transfer. ## Sources - AMLR Art. 3 — CELEX 32024R1624 - GwG SR 955.0, Art. 2 - GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 2 Abs. 1 Bst. c, 3bis-3quater, 4 Bst. f, 4bis, 4ter, 5 - GwG (rev.), Art. 2b - GwG SR 955.0, Art. 8a - GwG SR 955.0, Art. 2a Abs. 1 Bst. c, Abs. 5