# AMLR Art. 52 — BO through ownership interest > TJPG Art. 4 has been in force since 1 October 2026 — see [[Effective-dates timeline]]. By 10 July 2029 the Commission must assess whether to lower the threshold (AMLR Art. 52(2)). - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]] - **Swiss provisions:** [[TJPG Art. 4 - BO definition- 25% of capital|TJPG Art. 4]] - **Detailed citation:** TJPG Art. 4 Abs. 1 (25% of capital or votes, direct/indirect, alone or in concert) ## What it requires An ownership interest means direct or indirect ownership of 25% or more of shares, voting rights or other ownership interest, including profit, other internal resources or liquidation-balance rights (Art. 52(1)); indirect ownership is calculated by multiplying and summing holdings across chains, all levels counted, unless Art. 54 applies. By 10 July 2029 the Commission may, by delegated act, lower the threshold for higher-risk categories of corporate entity, to a maximum 15% unless a risk-based higher figure (always below 25%) is warranted (Art. 52(2)-(3)). ## Swiss position TJPG Art. 4 Abs. 1 sets a single 25% threshold: any natural person who ultimately controls a company by holding, directly or indirectly, alone or in concert with third parties, at least 25% of the capital or votes, or who controls it in another way, is the beneficial owner for register purposes. Where no one meets that test, Art. 4 Abs. 2 substitutes the senior-most member of the company's governing body as beneficial owner. TJPG Art. 4 does not set out a calculation methodology for indirect chains comparable to AMLR Art. 52(1), and has no sector- or risk-based variation of the threshold. ## Key divergences The baseline threshold is the same - 25%, direct or indirect; only TJPG Art. 4 adds 'alone or in concert with third parties'. The regimes diverge on flexibility and detail. AMLR Art. 52(2)-(3) gives the Commission power to lower the threshold, by delegated act, for higher-risk categories of corporate entity (maximum 15%, or a risk-justified figure always below 25%); TJPG Art. 4 has one flat threshold with no lowering mechanism or sectoral carve-out. AMLR Art. 52(1) prescribes how indirect ownership is calculated across ownership chains (multiplied, then summed) and requires all levels of ownership to be considered; TJPG Art. 4 states the threshold without a comparable calculation rule, leaving indirect and other control to be specified by the Federal Council under TJPG Art. 6. AMLR Art. 52(4) covers legal entities other than corporate entities where ownership cannot be calculated (the beneficial owners are those who control via other means, Art. 53(3)-(4)); TJPG Art. 4 Abs. 2 is a different rule, a fallback to the senior-most governing-body member when no one meets the 25% or control test. ## Effective dates TJPG Art. 4 has been in force since 1 October 2026 — see [[Effective-dates timeline]]. By 10 July 2029 the Commission must assess whether to lower the threshold (AMLR Art. 52(2)). ## 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]] — Same 25% threshold, measured on votes or capital (AMLR: shares, voting rights or other ownership interest incl. profit and liquidation rights), for operating legal persons and partnerships; listed companies are exempt (Art. 22). No indirect-chain calculation rule and no power to lower the threshold. *(direct)* - [[GwV-FINMA Art. 56 - Controlling person – principle|GwV-FINMA Art. 56]] — Same 25% threshold, expressed as votes or capital, direct or indirect and alone or in concert, for unlisted operating entities and their majority-controlled subsidiaries (Art. 52(1) speaks of shares, voting rights or other ownership interest and has no "in concert" wording). No chain-multiplication rule as in Art. 52(1) and no mechanism to lower the threshold. *(direct)* - [[GwG Art. 2a - Definitions (incl. politically exposed persons|GwG Art. 2a]] — Same 25% threshold, expressed as capital or votes, direct or indirect and alone or in concert with third parties (the "in concert" wording is Swiss only), in the statutory definition of the beneficial owner of an operating legal person. No indirect-chain calculation rule. *(direct)* - [[GwV-FINMA Art. 2 - Definitions|GwV-FINMA Art. 2]] — Ordinance definition of the controlling person (Bst. f) uses a similar 25% votes-or-capital threshold, direct or indirect, alone or in concert, or control in another way, and names the managing person as fallback. It is a definition only, with no chain calculation. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 52 — English text (EUR-Lex, CELEX 32024R1624) > **Article 52** > *Beneficial ownership through ownership interest* > 1. For the purpose of Article 51, first paragraph, point (a), ‘an ownership interest in the corporate entity’ shall mean direct or indirect ownership of 25 % or more of the shares or voting rights or other ownership interest in the corporate entity, including rights to a share of profits, other internal resources or liquidation balance. The indirect ownership shall be calculated by multiplying the shares or voting rights or other ownership interests held by the intermediate entities in the chain of entities in which the beneficial owner holds shares or voting rights and by adding together the results from those various chains, unless Article 54 applies. > For the purposes of assessing whether an ownership interest exists in the corporate entity, all shareholdings on every level of ownership shall be taken into account. > 2. Where Member States identify pursuant to Article 8(4), point (c), of Directive (EU) 2024/1640 categories of corporate entities that are exposed to higher money laundering and terrorist financing risks, including based on the sectors in which they operate, they shall inform the Commission thereof. By 10 July 2029, the Commission shall assess whether the risks associated with those categories of legal entities are relevant for the internal market and, where it concludes that a lower threshold is appropriate to mitigate those risks, adopt delegated acts in accordance with Article 85 to amend this Regulation by identifying: > (a) the categories of corporate entities that are associated with higher money laundering and terrorist financing risks and for which a lower threshold shall apply; > (b) the related thresholds. > The lower threshold referred to in the first subparagraph shall be set at a maximum of 15 % of ownership interest in the corporate entity, unless the Commission concludes, on the basis of risk, that a higher threshold would be more proportionate, which shall in any case be set at less than 25 %. > 3. The Commission shall review the delegated act referred to in paragraph 2 on a regular basis to ensure that it identifies the relevant categories of corporate entities that are associated with higher risks, and that the related thresholds are commensurate with those risks. > 4. In the case of legal entities other than corporate entities, for which, having regard to their form and structure, it is not appropriate or possible to calculate ownership, the beneficial owners shall be the natural persons who control via other means, directly or indirectly, the legal entity, pursuant to Article 53(3) and (4), except where Article 57 applies. ## Sources - AMLR Art. 52 — CELEX 32024R1624 - TJPG BBl 2025 2900, Art. 4