# AMLR Art. 7 — Prior notification of exemptions > GwG Art. 2 Abs. 4ter and Abs. 5 have been in force since 1 October 2026. AMLR Art. 7 applies from 10 July 2027; the backward-notification deadline for pre-existing exemptions is 10 October 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** _none_ - **Swiss provisions:** _none_ - **Detailed citation:** - ## What it requires Member States intending to grant an exemption under AMLR Art. 4-6 must notify the Commission without delay, with a justification grounded in their risk assessment. The Commission has 2 months to confirm the exemption or block it by reasoned decision, and may request further information. Only after confirmation may the Member State adopt the exemption, and it must review such decisions regularly. Existing exemptions under the predecessor directive must be notified by 10 October 2027, and the Commission publishes the full list annually. ## Swiss position Switzerland, not being a Member State, has no notify-the-Commission procedure. Exemptions from the GwG's scope are instead set directly in the statute: GwG Art. 2 Abs. 4ter (rev., in force 1.10.2026) lists specific low-risk transactions excluded from the adviser regime (e.g. family/inheritance-law transfers, transactions below CHF 5 million paid through a bank or other financial intermediary subject to the GwG, owner-occupied homes, agricultural-land transfers, organ functions for operating entities), and Abs. 5 gives the Federal Council power to create further exemptions from the adviser categories (Abs. 3bis-3ter) by ordinance. There is no supranational confirmation step and no published EU-style annual list. ## Key divergences The mechanisms are structurally different rather than comparable on the same axis. AMLR Art. 7 is a supranational check on a national discretion already granted by Art. 4-6: a Member State may exempt, but only after Commission confirmation, and the exemptions and their justifications are published annually. Switzerland's exemptions are set unilaterally, partly directly in the GwG text (Art. 2 Abs. 4ter) and partly through a Federal Council ordinance-making power (Abs. 5), with no external confirmation and no equivalent public list requirement identified in the Swiss texts reviewed. The Swiss exemptions located are also narrower in target than AMLR Art. 4-6: they apply only to the adviser categories introduced by the 2025 GwG revision (Art. 2 Abs. 3bis-3quater), not to financial intermediaries generally, so they do not necessarily cover the same range of activity that Member States may exempt under AMLR Art. 4-6. ## Effective dates GwG Art. 2 Abs. 4ter and Abs. 5 have been in force since 1 October 2026. AMLR Art. 7 applies from 10 July 2027; the backward-notification deadline for pre-existing exemptions is 10 October 2027. See [[Effective-dates timeline]]. ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 7 — English text (EUR-Lex, CELEX 32024R1624) > **Article 7** > *Prior notification of exemptions* > 1. Member States shall notify the Commission of any exemption that they intend to grant in accordance with Articles 4, 5 and 6 without delay. The notification shall include a justification based on the relevant risk assessment carried out by the Member State to sustain the exemption. > 2. The Commission shall within 2 months of the notification referred to in paragraph 1 take one of the following actions: > (a) confirm that the exemption may be granted on the basis of the justification given by the Member State; > (b) by reasoned decision, declare that the exemption may not be granted. > For the purposes of the first subparagraph, the Commission may request additional information from the notifying Member State. > 3. Upon receipt of a confirmation by the Commission pursuant to paragraph 2, point (a), of this Article, Member States may adopt a decision granting the exemption. The decision shall state the reasons on which it is based. Member States shall review such decisions regularly, and in any case when they update their national risk assessment pursuant to Article 8 of Directive (EU) 2024/1640. > 4. By 10 October 2027, Member States shall notify to the Commission the exemptions granted pursuant to Article 2(2) and (3) of Directive (EU) 2015/849 in place on 10 July 2027. > 5. The Commission shall publish every year in the Official Journal of the European Union the list of exemptions granted pursuant to this Article and make that list publicly available on its website. ## Sources - AMLR Art. 7 — CELEX 32024R1624 - GwG SR 955.0, Art. 2 - GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 2 Abs. 1 Bst. c, 3bis-3quater, 4ter, 5