# Effective-dates timeline The Swiss changes landed **first** (1 October 2026); the AMLR applies from 10 July 2027 — so for a transitional period Switzerland applies new rules while the EU still has the old directives in place. | Date | What changes | |---|---| | **1 October 2026** | **GwG revision** in force (enacted 26.09.2025, BBl 2025 2899) — the adviser regime, new Art. 2b, 8b–8d, 9b, 12a and related, **except** the provisions on public-law notaries (*Urkundspersonen*; Art. 2 Abs. 3quater, 22a Abs. 1, 22b, 29 Abs. 1 Bst. h and Abs. 3, 35 Abs. 2 Bst. i), to be put into force later (AS 2026 322). See [[The adviser regime (2025 GwG revision)]]. | | **1 October 2026** | **TJPG** in force (enacted 26.09.2025, BBl 2025 2900) — the federal beneficial-ownership register. See [[The Swiss beneficial-owner split]]. | | **1 April 2027** | **TJPG Art. 30** discrepancy reporting by financial intermediaries applies, six months after the TJPG entered into force (TJPG Art. 54 Abs. 1). Where a company is not registered and confirms that it falls under the two-year period of TJPG Art. 51 Abs. 2, the intermediary need not report discrepancies until that period ends (Art. 54 Abs. 2). See [[TJPG Art. 30 - FI discrepancy report, 30 days\|TJPG Art. 30]]. | | **10 July 2027** | **AMLR** applies (Regulation (EU) 2024/1624, Art. 90). | | **10 July 2029** | AMLR applies to **football agents and professional football clubs** — the obliged entities in Art. 3(3)(n) and (o). | ## The AMLR text Art. 90: *"It shall apply from 10 July 2027, except in relation to obliged entities referred to in Article 3, points (3)(n) and (o), to which it shall apply from 10 July 2029."* Art. 3(3)(n) is **football agents**; Art. 3(3)(o) is **professional football clubs**, and only in respect of listed transaction types — with an investor, with a sponsor, with football agents or other intermediaries, and transactions for the purpose of a player's transfer. ## Why the football limb keeps coming up Switzerland hosts FIFA, UEFA and the IOC. The Swiss side has **no football-club or football-agent obliged-entity category**; instead it reaches sport through the *politically exposed person* definition — GwG Art. 2a Abs. 1 Bst. c covers senior figures at international sports federations, with Abs. 5 defining those federations as the IOC and the non-governmental organisations it recognises which regulate one or more official sports at world level. The two regimes therefore touch sport from opposite directions: the EU by regulating football clubs and agents as obliged entities, Switzerland by treating sports-federation officials as PEPs. Neither is a substitute for the other. ## Reading undated statements Where a node says a Swiss provision "does" something, it describes the law **as consolidated today** unless the node says otherwise. Art. 2b, 8b–8d, 9b, 12a, 29c and 41a GwG and the TJPG have been in force since 1 October 2026. The GwG provisions on public-law notaries (Art. 2 Abs. 3quater, 22a Abs. 1, 22b, 29 Abs. 1 Bst. h and Abs. 3, 35 Abs. 2 Bst. i, as amended) are **not yet in force**; the Federal Council will set the date. ## Sources - AMLR Art. 90 and Art. 3(3)(n), (o) — CELEX 32024R1624 - GwG revision BBl 2025 2899 · TJPG BBl 2025 2900 (both enacted 26.09.2025, in force 1.10.2026, except the GwG provisions on public-law notaries — AS 2026 322) - GwG SR 955.0, Art. 2a Abs. 1 Bst. c and Abs. 5