# No Swiss counterpart > [!important] Read this first > The AMLR is not the FATF standard. A missing Swiss counterpart to an AMLR article does not by itself indicate a FATF deficiency. These 21 AMLR articles have no Swiss provision with the same function in the Swiss texts reviewed (GwG, GwV-FINMA, TJPG, VSB 20, and the StGB and OR provisions in this map). This does not mean that no Swiss rule on the subject exists elsewhere. The grouping below is an editorial reading of the article notes, not a legal finding. **By category:** 13 structurally inapplicable · 3 different mechanism · 5 substantive gap. ## Structurally inapplicable (13) EU institutional, Member-State or internal-market mechanisms that cannot apply to a non-member state. - [[AMLR Art. 5 - Exemptions for professional football clubs|AMLR Art. 5]] — Football-club exemptions. The exemption presupposes the EU's football-club obliged-entity category (AMLR Art. 3(3)(o)); Swiss law has no such category, so there is nothing to exempt. - [[AMLR Art. 7 - Prior notification of exemptions|AMLR Art. 7]] — Prior notification of exemptions. A Member State–Commission procedure; Swiss exemptions are set directly in the GwG. - [[AMLR Art. 8 - Cross-border operations notification|AMLR Art. 8]] — Cross-border operations notification. Internal-market passporting between home and host supervisors. - [[AMLR Art. 56 - Notifications|AMLR Art. 56]] — Notifications. Member States notify the Commission of legal-entity types; not a beneficial-owner filing. - [[AMLR Art. 81 - FIU-EPPO cooperation|AMLR Art. 81]] — FIU–EPPO cooperation. The EPPO is an EU body; Switzerland is not a participant. - [[AMLR Art. 82 - Requests to EPPO|AMLR Art. 82]] — Requests to EPPO. As Art. 81. - [[AMLR Art. 83 - FIU-OLAF cooperation|AMLR Art. 83]] — FIU–OLAF cooperation. OLAF is a Commission body protecting the EU's financial interests. - [[AMLR Art. 84 - Requests to OLAF|AMLR Art. 84]] — Requests to OLAF. As Art. 83. - [[AMLR Art. 85 - Exercise of delegation|AMLR Art. 85]] — Exercise of delegation. Commission delegated acts with a Parliament and Council veto. - [[AMLR Art. 86 - Committee procedure|AMLR Art. 86]] — Committee procedure. EU comitology for implementing acts. - [[AMLR Art. 87 - Review|AMLR Art. 87]] — Review. Commission review and report to the EU legislature. - [[AMLR Art. 88 - Reports|AMLR Art. 88]] — Reports. Commission report due by 10 July 2030 on four set points. - [[AMLR Art. 89 - Relation to Directive (EU) 2015-849|AMLR Art. 89]] — Relation to Directive (EU) 2015/849. Converts references to the repealed directive. ## Different mechanism (3) Switzerland deals with the subject, but by a different kind of rule. - [[AMLR Art. 32 - Guidelines on ML-TF risks|AMLR Art. 32]] — Guidelines on ML/TF risks. AMLA issues these centrally; in Switzerland FINMA guidance, SRO regulations and national risk assessments cover the subject, with no single issuer or fixed review cycle. - [[AMLR Art. 43 - List of prominent public functions|AMLR Art. 43]] — List of prominent public functions. Switzerland defines PEPs by abstract category (GwG Art. 2a) and publishes no list of functions. - [[AMLR Art. 80 - Large-cash-payment limit|AMLR Art. 80]] — Large-cash-payment limit. Switzerland sets no cash limit; GwG Art. 8a instead triggers dealer due diligence above a cash threshold. ## Substantive gap (5) No Swiss rule on the subject was found in the texts reviewed. - [[AMLR Art. 14 - Whistleblowing and need for internal reporting channels|AMLR Art. 14]] — Whistleblowing and internal reporting channels. No duty to run an internal channel for reports of AML breaches; GwG Art. 11 only protects good-faith reporting to MROS. - [[AMLR Art. 15 - Situation of specific employees (natural person act means legal person liability)|AMLR Art. 15]] — Situation of specific employees. No Swiss provision says whether AML duties attach to the employee or to the employing legal person. - [[AMLR Art. 41 - Residence-by-investment applicants|AMLR Art. 41]] — Residence-by-investment applicants. No customer category defined by an investment-based residence application. - [[AMLR Art. 57 - BO for entities similar to express trust|AMLR Art. 57]] — Beneficial owners of entities similar to express trusts (foundations). The TJPG defines beneficial owners for trusts only, and foundations are not among the entity types in TJPG Art. 2 Abs. 1. Bank-side declarations (VSB 20 Art. 40, Form S) cover some of the same persons. - [[AMLR Art. 60 - Objects of a power - default takers|AMLR Art. 60]] — Objects of a power and default takers. TJPG Art. 15 does not capture either category; GwV-FINMA Art. 64 Abs. 1 Bst. e (a class of possible beneficiaries) is the nearest rule. See also [[No FATF keying]] and [[Welcome to the Gw Graph]].