# AMLR Art. 65 — Exceptions to obligations of legal entities and legal arrangements > The TJPG has been in force since 1 October 2026. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]] - **Swiss provisions:** [[TJPG Art. 3 - Exceptions- listed companies and -75%|TJPG Art. 3]] - **Detailed citation:** TJPG Art. 3 (exclusions) ## What it requires Articles 63 and 64 do not apply to (a) companies whose securities are admitted to trading on a regulated market, provided control is exercised exclusively by the natural persons holding the voting rights, no other legal entities or arrangements sit in the ownership/control structure, and — for foreign legal entities under Art. 67 — equivalent requirements exist under international standards; or (b) bodies governed by public law as defined in Directive 2014/24/EU, Art. 2(1), point (4). ## Swiss position TJPG Art. 3 excludes three categories from the Act's entire scope, not only from register-reporting duties: (a) legal entities whose participation rights are wholly or partly listed on a stock exchange, plus subsidiaries held more than 75% directly or indirectly by one or more such listed companies; (b) occupational-pension institutions and purpose-of-pension institutions supervised under BVG Art. 61 and 64a; (c) legal entities in which public bodies hold at least 75% of the participation rights, directly or indirectly. ## Key divergences TJPG Art. 3's listed-company exclusion removes the entity from the whole Act, whereas AMLR Art. 65(a) removes only the Art. 63/64 beneficial-ownership duties and attaches conditions the Swiss carve-out does not require: exclusive control by the natural persons holding voting rights, no other legal entity or arrangement in the ownership/control structure, and, for foreign entities, equivalent international-standard requirements. TJPG's subsidiary and public-body carve-outs use fixed percentage thresholds — more than 75% and at least 75% respectively — concepts absent from AMLR Art. 65 itself. TJPG Art. 3 Bst. b exempts occupational-pension institutions outright, a category with no counterpart in AMLR Art. 65. AMLR Art. 65(b)'s public-law-body exemption turns on the EU procurement-directive definition (Directive 2014/24/EU, Art. 2(1)(4)), a different legal test from TJPG's participation-threshold approach. ## Effective dates The TJPG has been in force since 1 October 2026. 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. 22 - Listed companies|VSB 20 Art. 22]] — Both relieve exchange-listed companies of BO information duties, at different levels: AMLR 65(a) lifts the entity's own Art. 63/64 duties, subject to conditions; VSB 20 Art. 22 only relieves a bank's customer of the controlling-person declaration, without AMLR's conditions but reserving Art. 24 Abs. 2. *(related)* - [[VSB 20 Art. 23 - Public authorities|VSB 20 Art. 23]] — Both relieve public bodies of BO information duties, at different levels: AMLR 65(b) lifts the entity's own Art. 63/64 duties for bodies governed by public law (Directive 2014/24/EU definition); VSB 20 Art. 23 only relieves a bank's customer that is a Behörde of the controlling-person declaration. *(related)* - [[GwV-FINMA Art. 58 - Exemptions from establishing controlling persons|GwV-FINMA Art. 58]] — Both exempt listed companies and public bodies, at different levels: AMLR 65 lifts the entity's own Art. 63/64 duties; GwV-FINMA Art. 58 relieves the intermediary of obtaining a controlling-person declaration, and also covers majority-held subsidiaries of listed companies and further intermediaries, pension institutions and simple partnerships (lit. c-f). *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 65 — English text (EUR-Lex, CELEX 32024R1624) > **Article 65** > *Exceptions to obligations of legal entities and legal arrangements* > Articles 63 and 64 shall not apply to: > (a) companies whose securities are admitted to trading on a regulated market, provided that: > (i) control over the company is exercised exclusively by the natural person with the voting rights; > (ii) no other legal entities or legal arrangements are part of the company’s ownership or control structure; and > (iii) for foreign legal entities under Article 67, equivalent requirements to those referred to in subpoints (i) and (ii) of this point exist under international standards; > (b) bodies governed by public law as defined in Article 2(1), point (4), of Directive 2014/24/EU of the European Parliament and of the Council (43). ## Sources - AMLR Art. 65 — CELEX 32024R1624 - TJPG BBl 2025 2900, Art. 3