# AMLR Art. 79 — Anonymous accounts / bearer shares > AMLR Art. 79(3) bearer-share conversion deadline 10 July 2029, cancellation of unconverted shares from 10 July 2030; AMLR applies generally from 10 July 2027. StGB Art. 327a is inserted by the TJPG amending annex, in force 1 October 2026. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]], [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]] - **Swiss provisions:** [[GwG Art. 3 - Verification of the identity of|GwG Art. 3]], [[GwG Art. 4 - Establishing the beneficial owner|GwG Art. 4]], [[TJPG Art. 3 - Exceptions- listed companies and -75%|TJPG Art. 3]], [[CO Art. 622]], [[StGB Art. 327a]] - **Detailed citation:** GwG Art. 3-4; CO Art. 622 Abs. 1bis; StGB Art. 327a (new); TJPG Art. 3 Bst. a ## What it requires AMLR Art. 79 bans anonymous bank, payment and crypto-asset accounts, passbooks and safe-deposit boxes (Art. 79(1)), requiring CDD on any existing ones before further use; bars acquirers from accepting payments via anonymous prepaid cards issued in third countries absent a proven-low-risk RTS exception (Art. 79(2)); and prohibits companies from issuing bearer shares (listed companies and intermediated securities excepted), requiring conversion, immobilisation or deposit of existing ones by 10 July 2029, with unconverted shares losing voting and distribution rights from then and being cancelled from 10 July 2030, plus a ban on non-intermediated bearer share warrants (Art. 79(3)). ## Swiss position Swiss law has required identification of the contracting party since 1998; GwG Art. 3 and GwG Art. 4 leave no room for an anonymous-account regime, so there is nothing to abolish. Bearer shares are addressed by company law: CO Art. 622 Abs. 1bis permits them only where the company has listed securities or holds the shares as intermediated securities (Bucheffekten) deposited with a designated custodian; other existing bearer shares were converted to registered shares by operation of law 18 months after Abs. 1bis entered into force, under the transitional provisions to the 2019 Global Forum act (BG vom 21. Juni 2019, Art. 4). TJPG Art. 3 Bst. a exempts listed companies from the beneficial-ownership register on the same listing rationale. StGB Art. 327a, inserted by the TJPG annex in place of the repealed Art. 327, fines the intentional failure to properly keep a company's share, unit or membership register (e.g. the AG share register under CO Art. 686), or the TJPG holder register for foreign entities administered in Switzerland. ## Key divergences AMLR Art. 79 addresses three distinct anonymity risks in one article; Swiss law reaches them through separate, older instruments rather than one AML prohibition. The account limb is already resolved by the 1998 identification duty, so there is no 'abolition' to record. Bearer shares are handled by company law: CO Art. 622 Abs. 1bis permits bearer shares only for listed companies or intermediated securities (the 2019 transitional provisions converted all other bearer shares into registered shares), mirrored on the register side by the TJPG Art. 3 Bst. a listing exemption. AMLR Art. 79(3) additionally bars non-intermediated bearer share warrants specifically; no Swiss provision addressing bearer share warrants as such was found in the Swiss texts reviewed. Likewise, Art. 79(2)'s ban on acquirers accepting anonymous third-country prepaid cards has no located Swiss counterpart. StGB Art. 327a is a criminal backstop for register-keeping generally across several entity types, not an offence targeted at bearer shares as such. ## Effective dates AMLR Art. 79(3) bearer-share conversion deadline 10 July 2029, cancellation of unconverted shares from 10 July 2030; AMLR applies generally from 10 July 2027. StGB Art. 327a is inserted by the TJPG amending annex, in force 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. 5 - Bearer savings books|VSB 20 Art. 5]] — Both prohibit bearer or anonymous savings books. AMLR requires CDD before an existing one is used; VSB requires termination on first presentation and identification of whoever withdraws. *(direct)* - [[VSB 20 Art. 4 - Identifying the contracting partner|VSB 20 Art. 4]] — VSB 20 Art. 4 requires the bank to identify the contracting partner on opening accounts, savings books, custody accounts and safe-deposit boxes but contains no express ban on anonymous accounts, which AMLR Art. 79(1) states and extends to crypto-asset accounts. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 79 — English text (EUR-Lex, CELEX 32024R1624) > **Article 79** > *Anonymous accounts and bearer shares and bearer share warrants* > 1. Credit institutions, financial institutions and crypto-asset service providers shall be prohibited from keeping anonymous bank and payment accounts, anonymous passbooks, anonymous safe-deposit boxes or anonymous crypto-asset accounts as well as any account otherwise allowing for the anonymisation of the customer account holder or the anonymisation or increased obfuscation of transactions, including through anonymity-enhancing coins. > Owners and beneficiaries of existing anonymous bank or payment accounts, anonymous passbooks, anonymous safe-deposit boxes held by credit institutions or financial institutions, or crypto-asset accounts shall be subject to customer due diligence measures before those accounts, passbooks, or deposit boxes are used in any way. > 2. Credit institutions and financial institutions acting as acquirers within the meaning of Article 2, point (1), of Regulation (EU) 2015/751 of the European Parliament and of the Council (46) shall not accept payments carried out with anonymous prepaid cards issued in third countries, unless otherwise provided for in the regulatory technical standards adopted by the Commission in accordance with Article 28 of this Regulation on the basis of a proven low risk. > 3. Companies shall be prohibited from issuing bearer shares, and shall convert all existing bearer shares into registered shares, shall immobilise them within the meaning of Article 2(1), point (3), of Regulation (EU) No 909/2014, or deposit them with a financial institution by 10 July 2029. However, companies with securities listed on a regulated market or whose shares are issued as intermediated securities either through immobilisation within the meaning of Article 2(1), point (3), of that Regulation or through a direct issuance in dematerialised form within the meaning of Article 2(1), point (4), of that Regulation shall be permitted to issue new and maintain existing bearer shares. For existing bearer shares that are not converted, immobilised or deposited by 10 July 2029, all voting rights and rights to distribution attached to those shares shall be automatically suspended until their conversion, immobilisation or deposit. All such shares not converted, immobilised or deposited by 10 July 2030 shall be cancelled, leading to a share capital decrease of the corresponding amount. > Companies shall be prohibited from issuing bearer share warrants that are not in intermediated form. ## Sources - AMLR Art. 79 — CELEX 32024R1624 - GwG SR 955.0, Art. 3, Art. 4 - TJPG BBl 2025 2900, Art. 3 Bst. a - CO (OR) SR 220, Art. 622 - StGB SR 311.0, Art. 327 (repealed), Art. 327a — inserted via TJPG amending annex