# AMLR Art. 67 — Foreign legal entities and foreign legal arrangements > TJPG in force 1 October 2026 (BBl 2025 2900). AMLR Art. 67 applies from 10 July 2027; Art. 67(7) sets a 10 January 2028 deadline for pre-existing real-estate holdings (with a 1 January 2014 carve-out). - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]], [[FATF R.25 - Transparency and beneficial ownership of legal arrangements|FATF R.25]] - **Swiss provisions:** [[TJPG Art. 2 - Scope- AG, KmAG, GmbH, cooperatives|TJPG Art. 2]], [[TJPG Art. 17 - Foreign legal entities- Art. 4-14|TJPG Art. 17]], [[TJPG Art. 40 - Foreign entity acquiring CH real|TJPG Art. 40]] - **Detailed citation:** TJPG Art. 2 Abs. 1 Bst. b; Art. 17 (foreign legal entities); Art. 40 (land register proof) ## What it requires Non-EU legal entities and trustees of express trusts administered or established outside the Union must submit beneficial-ownership information to the central register of the relevant Member State where they enter a business relationship with an obliged entity (for legal entities only if the Art. 67(2) risk conditions are met), acquire EU real estate, buy certain high-value goods, or win a public contract. Submission timing depends on the trigger (before the relationship, purchase or contract signature), and changes must be reported within 28 days for as long as the trigger relationship continues. ## Swiss position TJPG Art. 2 Abs. 1 Bst. b sets the CH nexus: a registered CH branch, effective administration in Switzerland, or ownership/acquisition of CH real estate under BewG Art. 4. TJPG Art. 17 Abs. 1 applies Art. 4-14 (beneficial-ownership identification and reporting) by analogy to these foreign entities; Abs. 2 requires them to designate a CH representative or service address on registration. Art. 40 requires proof of Transparenzregister entry when acquiring CH real estate under BewG Art. 4; without it the land registrar suspends registration and gives a 10-day cure period before refusing entry under ZGB Art. 966. ## Key divergences Both regimes reach foreign entities that acquire real estate (TJPG Art. 2 also uses a Swiss branch or effective administration in Switzerland; AMLR Art. 67 also uses a business relationship), but TJPG Art. 40 backs its real-estate trigger with a land-registry gate - the registrar can suspend or refuse registration for missing proof - a mechanism AMLR Art. 67 has no equivalent of. AMLR Art. 67(1)(c)-(d) also reaches entities through high-value goods purchases (motor vehicles, watercraft, aircraft above set EUR thresholds) and public contracts/concessions, categories TJPG Art. 2 does not use as CH nexus triggers. AMLR requires updates within 28 days and submission before purchase or contract signature; TJPG Art. 17 applies the one-month deadlines of Art. 9-10 by analogy, and Art. 40 adds a 10-day period at the land registry to cure missing proof. ## Effective dates TJPG in force 1 October 2026 (BBl 2025 2900). AMLR Art. 67 applies from 10 July 2027; Art. 67(7) sets a 10 January 2028 deadline for pre-existing real-estate holdings (with a 1 January 2014 carve-out). ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 67 — English text (EUR-Lex, CELEX 32024R1624) > **Article 67** > *Foreign legal entities and foreign legal arrangements* > 1. Legal entities created outside the Union and trustees of express trusts or persons holding an equivalent position in a similar legal arrangement that are administered outside the Union or that reside or are established outside the Union shall submit beneficial ownership information pursuant to Article 62 to the central register of the Member State where they: > (a) enter into a business relationship with an obliged entity; > (b) acquire real estate in the Union, whether directly or through intermediaries; > (c) acquire, whether directly or through intermediaries, any of the following goods from persons trading as referred to in Article 3, points (3) (f) and (j), in the context of an occasional transaction: > (i) motor vehicles for non-commercial purposes for a price of at least EUR 250 000 or the equivalent in national currency; > (ii) watercraft for non-commercial purposes for a price of at least EUR 7 500 000 or the equivalent in national currency; > (iii) aircraft for non-commercial purposes for a price of at least EUR 7 500 000 or the equivalent in national currency; > (d) are awarded a public contract for goods or services, or concessions by a contracting authority in the Union. > 2. By way of derogation from paragraph 1, point (a), where legal entities created outside the Union enter into a business relationship with an obliged entity, they shall only submit their beneficial ownership information to the central register where: > (a) they enter into a business relationship with an obliged entity that is associated with medium-high or high money laundering and terrorist financing risks pursuant to the risk assessment at Union level or the national risk assessment of the Member State concerned referred to in Articles 7 and 8 of Directive (EU) 2024/1640; or > (b) the risk assessment at Union level or the national risk assessment of the Member State concerned identifies that the category of legal entity or the sector in which the legal entity created outside the Union operates is associated, where relevant, with medium-high or high money laundering and terrorist financing risks. > 3. The beneficial ownership information shall be accompanied by a statement setting out in relation to which of those activities the information is submitted, as well as any relevant document, and shall be submitted: > (a) for the cases referred to in paragraph 1, point (a), prior to start of the business relationship; > (b) for the cases referred to in paragraph 1, points (b) and (c), before completion of the purchase; > (c) for the cases referred to in paragraph 1, point (d), before signature of the contract. > 4. For the purposes of paragraph 1, point (a), obliged entities shall inform the legal entities where the conditions laid down in paragraph 2 are met and require a certificate of proof of registration or an excerpt of the beneficial ownership information held in the central register to proceed with the business relationship or occasional transaction. > 5. In the cases covered by paragraph 1, legal entities created outside the Union and trustees of express trusts or persons holding an equivalent position in a similar legal arrangement that are administered outside the Union or that reside or are established outside the Union shall report any change to the beneficial ownership information submitted to the central register pursuant to paragraph 1 without undue delay, and in any case, within 28 calendar days thereof. > The first subparagraph shall apply: > (a) for the cases referred to in paragraph 1, point (a), for the entire duration of the business relationship with the obliged entity; > (b) for the cases referred to in paragraph 1, point (b), for as long as the legal entity or legal arrangement owns the real estate; > (c) for the cases referred to in paragraph 1, point (c), for the period between the initial submission of the information to the central register and the completion of the purchase; > (d) for the cases referred to in paragraph 1, point (d), for the entire duration of the contract. > 6. Where the legal entity, the trustee of the express trust or the person holding an equivalent position in a similar legal arrangement meets the conditions laid down in paragraph 1 in different Member States, a certificate of proof of registration of the beneficial ownership information in a central register held by one Member State shall be considered as sufficient proof of registration. > 7. Where, on 10 July 2027, legal entities created outside the Union or legal arrangements administered outside the Union or whose trustee or person holding an equivalent position in a similar legal arrangement resides or is established outside the Union own, whether directly or through intermediaries, real estate, the beneficial ownership information of those legal entities and legal arrangements shall be submitted to the central register and accompanied by a justification for that submission by 10 January 2028. > However, the first subparagraph shall not apply to legal entities or legal arrangements that have acquired real estate in the Union prior to 1 January 2014. > Member States may decide, on the basis of risk, that an earlier date applies and notify the Commission thereof. The Commission shall communicate such decisions to the other Member States. > 8. Member States may, on the basis of risk, extend the obligation set out in paragraph 1, point (a), to business relationships with foreign legal entities that are ongoing on 10 July 2027 and notify the Commission thereof. The Commission shall communicate such decisions to the other Member States. ## Sources - AMLR Art. 67 — CELEX 32024R1624 - TJPG SR — BBl 2025 2900, Art. 2, 17, 40