# AMLR Art. 51 — Identify BO of legal entities > The TJPG (Art. 4, 6, 7) has been in force since 1 October 2026. See [[Effective-dates timeline]]. GwG Art. 4 and GwV-FINMA Art. 56 apply today. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]] - **Swiss provisions:** [[GwG Art. 4 - Establishing the beneficial owner|GwG Art. 4]], [[GwV-FINMA Art. 56 - Controlling person – principle|GwV-FINMA Art. 56]], [[TJPG Art. 4 - BO definition- 25% of capital|TJPG Art. 4]], [[TJPG Art. 6 - Indirect and other control|TJPG Art. 6]], [[TJPG Art. 7 - Duty to identify and verify|TJPG Art. 7]], [[VSB 20]] - **Detailed citation:** TJPG Art. 4, 6, 7; GwG Art. 4; GwV-FINMA Art. 56 > [!tip] In practice > - Swiss law uses the same test (25% of capital or votes, or control by other means) in three places: GwG Art. 2a Abs. 3 and GwV-FINMA Art. 56 for due diligence, and TJPG Art. 4 for the register. > - The AMLR requires identifying control by other means in parallel with ownership. TJPG Art. 4 states ownership and control as alternatives. > - The listed-company exemptions differ: GwG Art. 4 (listed companies and their majority-controlled subsidiaries) and TJPG Art. 3 (subsidiaries more than 75% held). > - For banks, this runs through VSB 20. ## What it requires Beneficial owners of a legal entity are the natural persons who have, directly or indirectly, an ownership interest in the corporate entity (point (a)), or who control the entity, directly or indirectly, through ownership interest or via other means (point (b)). Control via other means must be identified independently of, and in parallel to, any ownership interest or control exercised through ownership interest. ## Swiss position Switzerland splits this across three concepts - see [[The Swiss beneficial-owner split]]. GwG Art. 4 requires establishing the wirtschaftlich berechtigte Person with due care, with a written declaration required in the circumstances at Art. 4 Abs. 2; GwV-FINMA Art. 56 requires a written declaration of the Kontrollinhaber holding at least 25% of capital or votes, or controlling by other means, for unlisted operating entities and partnerships. For banks this identification runs through VSB 20 instead (see [[Scope note — GwV-FINMA Title 5 vs VSB 20]]). The TJPG register - in force from 1 October 2026, see [[Effective-dates timeline]] - defines beneficial owner at TJPG Art. 4 (25% of capital or votes, or other control) and requires the company to identify and verify them under TJPG Art. 7, with TJPG Art. 6 delegating indirect or other control to the Federal Council. ## Key divergences AMLR Art. 51 defines one beneficial-owner concept for the entity, covering ownership interest and control alike. For operating legal entities, GwG Art. 2a Abs. 3, GwV-FINMA Art. 56 and TJPG Art. 4 use the same test (25% of capital or votes, or control in another way), in separate instruments for intermediary due diligence and for the register - see [[The Swiss beneficial-owner split]]. AMLR Art. 51(b) requires identifying control independently of and in parallel to ownership interest; TJPG Art. 4 instead states ownership and control as alternatives, with the coexistence question addressed separately in AMLR Art. 54, not here. GwG Art. 4 exempts listed companies and their majority-controlled subsidiaries from the establishment duty; TJPG Art. 3 Bst. a instead exempts listed companies, and subsidiaries more than 75% held by them, from the Act altogether. For banks, delivery runs through VSB 20 rather than GwV-FINMA Title 5. ## Effective dates The TJPG (Art. 4, 6, 7) has been in force since 1 October 2026. See [[Effective-dates timeline]]. GwG Art. 4 and GwV-FINMA Art. 56 apply today. ## 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. 20 - Establishing the controlling persons|VSB 20 Art. 20]] — Bank cascade for operating entities: 25% holders (Abs. 1), then other controllers (Abs. 3), then managing person (Abs. 4). Control is a fallback step, not parallel as in Art. 51. *(direct)* - [[GwG Art. 2a - Definitions (incl. politically exposed persons|GwG Art. 2a]] — Statutory BO definition for operating legal persons: at least 25% of capital or votes, alone or in concert, or control otherwise; senior governing-body member as fallback. *(direct)* - [[VSB 20 Art. 39 - Domiciliary companies|VSB 20 Art. 39]] — For domiciliary companies (non-operating legal entities, Abs. 2) the bank obtains a declaration on Formular A of who is beneficially entitled to the assets (Abs. 1). The test is entitlement to assets, not Art. 51's ownership and control. *(related)* - [[GwV-FINMA Art. 63 - Domiciliary companies|GwV-FINMA Art. 63]] — For domiciliary companies the intermediary obtains a written declaration of the beneficial owner (Abs. 1). The Swiss test is entitlement to assets, not Art. 51's ownership and control. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 51 — English text (EUR-Lex, CELEX 32024R1624) > **Article 51** > *Identification of beneficial owners for legal entities* > Beneficial owners of legal entities shall be the natural persons who: > (a) have, directly or indirectly, an ownership interest in the corporate entity; or > (b) control, directly or indirectly, the corporate or other legal entity, through ownership interest or via other means. > Control via other means as referred to in the first paragraph, point (b), shall be identified independently of and in parallel to the existence of an ownership interest or control through ownership interest. ## Sources - AMLR Art. 51 — CELEX 32024R1624 - GwG SR 955.0, Art. 4 - GwV-FINMA SR 955.033.0, Art. 56 - TJPG BBl 2025 2900, Art. 4 - TJPG BBl 2025 2900, Art. 6 - TJPG BBl 2025 2900, Art. 7