# AMLR Art. 33 — Simplified due diligence > GwG Art. 8c (advisers) is in force 1 October 2026. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]] - **Swiss provisions:** [[GwG Art. 8c - Simplified or enhanced adviser CDD|GwG Art. 8c]], [[GwV-FINMA Art. 11 - Waiver of due diligence obligations|GwV-FINMA Art. 11]], [[GwV-FINMA Art. 12 - Simplified due diligence obligations|GwV-FINMA Art. 12]] - **Detailed citation:** GwV-FINMA Art. 11-12; GwG Art. 8c (advisers, new) ## What it requires Where risk factors show a low-risk relationship or transaction, obliged entities may apply listed simplified measures - delayed verification of customer/beneficial-owner identity (up to 60 days), less frequent updates, reduced purpose-and-nature information, or lighter transaction scrutiny - proportionate to the business and the lower risk identified, and set out in internal procedures. Ongoing monitoring, periodic re-verification of the low-risk conditions, and a duty to revert to normal diligence in five listed circumstances (doubts, disappearance of the low-risk factors, suspicion, sanctions evasion) remain mandatory throughout. ## Swiss position GwV-FINMA Art. 11 sets fixed, ordinance-level thresholds below which due diligence is dispensed with for defined non-cash payment-instrument relationships (e.g. CHF 1,000 per transaction / 5,000 per year, or CHF 5,000 per month / 25,000 per year for merchant payments), and GwV-FINMA Art. 12 relieves payment-instrument issuers of retaining identification-document copies where a bank delegation agreement applies. GwG Art. 7a separately lets a financial intermediary waive the Art. 3-7 due-diligence duties entirely for relationships involving only low-value assets, absent any suspicion. For advisers, new GwG Art. 8c makes the scope of due diligence risk-based and delegates the calibration of simplified or enhanced duties to SRO regulations. ## Key divergences AMLR Art. 33 builds a proportionate, risk-based simplified-diligence regime that still requires ongoing monitoring and periodic reassessment of the low-risk conditions. Swiss law instead works through fixed CHF-denominated thresholds (GwV-FINMA Art. 11-12) below which the intermediary may waive due diligence for defined payment-instrument categories (transaction monitoring under Art. 14 and 20 remains), plus a general low-value-assets waiver of the full Art. 3-7 duty set (GwG Art. 7a) that has no AMLR counterpart of that shape - the closest AMLR rule is the supervisor-granted exemption for low-value e-money (Art. 19(7)). For advisers, Switzerland delegates the entire simplified/enhanced calibration to SRO regulation under GwG Art. 8c, giving Switzerland two separate simplified-diligence regimes - statute- and ordinance-level for financial intermediaries, SRO-level for advisers - rather than the single statutory regime AMLR Art. 33 sets for all obliged entities. ## Effective dates GwG Art. 8c (advisers) is in force 1 October 2026. ## 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.* - [[GwG Art. 7a - Assets of low value (de|GwG Art. 7a]] — GwG Art. 7a lets an intermediary waive the Art. 3–7 due diligence duties altogether where only low-value assets are involved and there is no suspicion (a value test); AMLR Art. 33 only permits listed simplified measures where risk is low (a risk test) and withdraws them on suspicion. *(related)* - [[GwG Art. 6 - Special due diligence obligations (clarification|GwG Art. 6]] — GwG Art. 6(1) scales the extent of purpose-and-nature information and the periodicity of controls to the customer's risk; AMLR Art. 33(1)(c)–(d) lets obliged entities reduce purpose-and-nature information and the frequency or degree of transaction scrutiny where risk is low, within listed conditions. *(related)* - [[FATF R.1 - Assessing risks and applying a risk-based approach|FATF R.1 — Assessing risks and applying a risk-based approach]] — R.1 requires countries to permit simplified measures for lower risk; AMLR Art. 33 is the EU rule that lets obliged entities apply them, within listed conditions. *(direct)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 33 — English text (EUR-Lex, CELEX 32024R1624) > **Article 33** > *Simplified due diligence measures* > 1. Where, taking into account the risk factors set out in Annexes II and III, the business relationship or transaction present a low degree of risk, obliged entities may apply the following simplified due diligence measures: > (a) verifying the identity of the customer and the beneficial owner after the establishment of the business relationship, provided that the specific lower risk identified justified such postponement, but in any case no later than 60 days of the relationship being established; > (b) reducing the frequency of customer identification updates; > (c) reducing the amount of information collected to identify the purpose and intended nature of the business relationship or occasional transaction or inferring it from the type of transactions or business relationship established; > (d) reducing the frequency or degree of scrutiny of transactions carried out by the customer; > (e) applying any other relevant simplified due diligence measure identified by AMLA pursuant to Article 28. > The measures referred to in the first subparagraph shall be proportionate to the nature and size of the business and to the specific elements of lower risk identified. However, obliged entities shall carry out sufficient monitoring of the transactions and business relationship to enable the detection of unusual or suspicious transactions. > 2. Obliged entities shall ensure that the internal procedures established pursuant to Article 9 contain the specific measures of simplified verification that shall be taken in relation to the different types of customers that present a lower risk. Obliged entities shall document decisions to take into account additional factors of lower risk. > 3. For the purpose of applying simplified due diligence measures referred to in paragraph 1, point (a), obliged entities shall adopt risk management procedures with respect to the conditions under which they can provide services or perform transactions for a customer prior to the verification taking place, including by limiting the amount, number or types of transactions that can be performed or by monitoring transactions to ensure that they are in line with the expected norms for the business relationship at hand. > 4. Obliged entities shall verify on a regular basis that the conditions for the application of simplified due diligence measures continue to exist. The frequency of such verifications shall be commensurate with the nature and size of the business and the risks posed by the specific relationship. > 5. Obliged entities shall refrain from applying simplified due diligence measures in any of the following situations: > (a) the obliged entities have doubts as to the veracity of the information provided by the customer or the beneficial owner at the stage of identification, or they detect inconsistencies regarding that information; > (b) the factors indicating a lower risk are no longer present; > (c) the monitoring of the customer’s transactions and the information collected in the context of the business relationship exclude a lower risk scenario; > (d) there is a suspicion of money laundering or terrorist financing; > (e) there is a suspicion that the customer, or the person acting on behalf of the customer, is attempting to circumvent or evade targeted financial sanctions. ## Sources - AMLR Art. 33 — CELEX 32024R1624 - GwG (as amended, BBl 2025 2899), Art. 8c - GwV-FINMA SR 955.033.0, Art. 11 - GwV-FINMA SR 955.033.0, Art. 12 - GwG SR 955.0, Art. 7a