# CH ⇄ EU AML concordance A navigable map of how the **Swiss** anti-money-laundering and beneficial-ownership regime lines up, article by article, against the **EU AML package**, with the **FATF Recommendations** as the shared spine. Built for legal and compliance professionals who need to see the Swiss, EU and FATF positions on a single question side by side. Created and maintained by **[Lucian Schwartz-Croft](https://www.linkedin.com/in/lucian-schwartz-croft-04336924a/)**. **Law as at 1 October 2026.** Swiss texts as consolidated on 1 October 2026 (GwV-FINMA: as at 1 January 2023, its latest version); FATF Recommendations as updated June 2026; AMLR as adopted. > [!warning] Not legal advice > This map is a research and reference aid, not legal advice, and using it creates no > lawyer–client relationship. It **summarises** primary legal texts and may be incomplete, > simplified, or out of date. Nothing here asserts that any two provisions are legally > equivalent. Always verify against the official sources and take qualified advice before > relying on any point. **Start here:** [[AMLR]] · [[FATF Recommendations]] · [[VSB 20]] · [[The Swiss beneficial-owner split]] · [[The adviser regime (2025 GwG revision)]] · [[Effective-dates timeline]] · [[No Swiss counterpart]] · [[_index|Map index]] --- ## What this is Three bodies of law, cross-referenced at the level of the individual article: - **EU** — the Anti-Money-Laundering Regulation, **AMLR** (Regulation (EU) 2024/1624): 90 articles. - **FATF** — all 40 Recommendations (2012, as updated June 2026); 23 of them are keyed directly to AMLR articles, and the others are linked where a real correspondence exists. - **Switzerland** — 138 provisions across the money-laundering statute and its ordinances: the **GwG** (SR 955.0), **GwV-FINMA** (SR 955.033.0), the new transparency-register act **TJPG**, the core criminal offences of the **StGB** (Art. 260ter, 260quinquies, 305bis, 305ter, 327a), and a few provisions of the Code of Obligations and other instruments — plus the 70 articles of the banks' due-diligence code **VSB 20**. Each AMLR article is joined to the FATF Recommendation(s) it answers to and to the specific Swiss provision(s) that do the same job. The result is one connected web you explore from any starting point, rather than a flat table you scroll. **At a glance:** 90 AMLR articles · 138 Swiss provisions · 70 VSB 20 articles · 40 FATF Recommendations · 21 AMLR articles with no Swiss counterpart · 15 with no FATF keying. --- ## An article-level crosswalk We are not aware of another public crosswalk that maps the Swiss AML/BO regime onto the EU package **and** the FATF standard at article level. This map is that crosswalk: a single classification that holds all three regimes in one frame, so a question asked on one side can be traced straight through to the others. What it deliberately does **not** do is pronounce legal equivalence. It records how the provisions correspond — same subject, same duty, same FATF criterion — and leaves the verdict (equivalent, different mechanism, no equivalent, or in conflict) to the professional reading it. The map is the evidence base for that judgment, not the judgment itself. --- ## Why it matters now Three forces are converging on the Swiss AML perimeter at once, and this map is built to read them together: - **Switzerland's next FATF mutual evaluation.** The forthcoming fifth-round evaluation scores the country against the very Recommendations used here as the spine. Tracing a Swiss provision to the FATF criterion it is meant to satisfy — and seeing where no Swiss provision is keyed — is exactly the technical-compliance question evaluators ask. - **A wave of Swiss financial-crime reform.** The 2025 GwG revision brings advisers (lawyers, notaries and other professional advisers) into scope and adds the new federal beneficial-ownership register (TJPG), both in force since **1 October 2026** — except the GwG provisions on public-law notaries (*Urkundspersonen*; Art. 2 Abs. 3quater, 22b and related), which the Federal Council will bring into force later. The map carries these new and amended provisions and flags what is not yet in force. - **The pull of EU law.** The AMLR creates a single EU rulebook, supervised by the new EU AML Authority (AMLA), applying from **10 July 2027**. Swiss institutions with an EU nexus, and Swiss law's own direction of travel, are increasingly measured against that standard. The map shows, provision by provision, where Switzerland already aligns and where it diverges. For a transitional period the Swiss changes landed *first*, so Switzerland is applying new rules against an EU regime whose predecessor directives are still in place — a gap this map makes visible. --- ## What's in each entry - **AMLR article** → *What it requires · Swiss position · Key divergences · Effective dates · Sources*, with links to its FATF and Swiss counterparts. - **Swiss provision** → a plain-language *Description* of what the article sets out, a *Context & interpretation* note on its practical significance and — where one exists — the landmark matter behind it (for example the FINMA BSI/1MDB and Credit Suisse–Mozambique cases on the due-diligence and organisational articles), and a *Serves AMLR* list of everything on the EU side it supports. - **FATF Recommendation** → a concise description, the AMLR articles keyed to it and, for the core Recommendations, the Swiss provisions that answer it directly. - **In practice** boxes on six frequently used AMLR articles (Art. 22, 24, 26, 51, 77 and 80) give the key points of the entry in a few lines. - **Every article entry** (except VSB 20 for now) also carries the **authoritative text** of the provision, copied verbatim from the official source, in a folded block at the end. **Orientation notes** unpack the structural traps a straight article-to-article reading misses — the Swiss beneficial-owner split, the 2025 adviser regime, the effective-dates timeline, and the GwV-FINMA Title 5 / VSB 20 scope point — and two "gap" lists collect the AMLR articles with no Swiss counterpart and the AMLR articles with no FATF keying. The [[No Swiss counterpart]] list sorts its 21 articles into three groups: structurally inapplicable, different mechanism and substantive gap. --- ## How to use it - **Start anywhere and follow the links.** Open an AMLR article to see the FATF Recommendation(s) it implements and the Swiss provision(s) that deliver the same duty; open a Swiss provision to see every AMLR article it serves. Move up, down and across the three regimes by clicking. - **Answer a real question.** *What is the Swiss counterpart to AMLR Art. 22?* *How does Switzerland meet FATF R.25 on trusts?* *Which AMLR obligations have no Swiss equivalent yet?* Each is a click or two from any entry. - **Read the divergences, not just the matches.** The value is often in the *Key divergences* and *Context* notes — where the Swiss mechanism differs in kind, splits a single EU concept in two, or reaches a subject from a different direction. - **Use the graph** to see the shape of the whole regime — see below. --- ## The graph The interactive graph is the primary analytical instrument. Every connection records only that two provisions address the same subject; the **structure** of those connections is what carries the meaning, and structure is what a graph shows and a table hides. At a glance you can see: - **Load-bearing Swiss rules** — a provision wired to many AMLR articles (the GwV-FINMA CDD and beneficial-owner articles fan out widely) is doing a large share of the regime's work. - **Where the core lives** — dense clusters around FATF R.10 (customer due diligence) and R.24/R.25 (beneficial ownership) mark where the two regimes are most tightly coupled. - **Over-connection** — an AMLR article that pulls in an entire Swiss chapter is a prompt to ask whether the mapping is too coarse. - **Gaps** — an AMLR node with no Swiss edge has no Swiss counterpart in the texts reviewed. The [[No Swiss counterpart]] list sorts these into EU mechanisms that cannot apply to a non-member state, subjects Switzerland handles by a different mechanism (the cash-payment limit, for example) and substantive gaps (residence-by-investment applicants, for example). The AMLR is not the FATF standard, so a missing Swiss counterpart does not by itself indicate a FATF deficiency. ## Out of scope - **The rest of the EU AML package.** The Sixth Anti-Money-Laundering Directive (AMLD6, Directive (EU) 2024/1640) and the AMLA Regulation (Regulation (EU) 2024/1620) are not mapped. The AMLR refers to them in places; those references are not followed here. - **Effectiveness.** The map compares legal texts. It does not assess how the rules are applied, supervised or enforced in practice, and it does not score Switzerland against the FATF effectiveness criteria. - **Draft and pending law.** Proposals and consultations, such as the GwV-FINMA revision consulted on in 2026, are not reflected until they are adopted. --- ## Sources & effective dates The map summarises official primary texts: - **AMLR** — Regulation (EU) 2024/1624 (EUR-Lex, CELEX 32024R1624). - **FATF** — the International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (the 40 Recommendations), 2012, updated June 2026. - **Switzerland** — GwG (SR 955.0, consolidated 1 October 2026), GwV-FINMA (SR 955.033.0, consolidated 1 January 2023, the latest version in force), StGB (SR 311.0) and OR (SR 220) (consolidated 1 October 2026), GwV (SR 955.01), the TJPG (BBl 2025 2900) and the GwG revision of 26 September 2025 (BBl 2025 2899), via Fedlex; and VSB 20 (Swiss Bankers Association). The Swiss revision and the TJPG register have applied since **1 October 2026** (the GwG provisions on public-law notaries are not yet in force), and financial intermediaries' discrepancy reporting under TJPG Art. 30 applies from **1 April 2027**; the AMLR applies from **10 July 2027**, and from **10 July 2029** for football agents and clubs. Where an entry cites a not-yet-in-force provision, it says so. --- ## About and maintenance > [!note] Draft — for owner approval This map is an independent project by [Lucian Schwartz-Croft](https://www.linkedin.com/in/lucian-schwartz-croft-04336924a/). It is not affiliated with, or endorsed by, any authority, standard-setter or association whose texts it covers. The map is revised when the underlying texts change. The *Law as at* line at the top shows the state of the law it reflects. Corrections and suggestions are welcome via LinkedIn. --- ## Legal notice **Not legal advice.** This map is provided for research and reference purposes only. It is not legal advice and does not create a lawyer–client relationship. It is provided "as is", without any warranty that it is accurate, complete or up to date. You use it at your own risk; to the extent permitted by law, the author accepts no liability for any loss arising from its use. **Non-commercial project.** This site is a personal, non-commercial project. It is not run for profit or for commercial gain: it charges no fees and carries no advertising, sponsorship or paid services. **Sources and reuse.** - **Swiss law** — Swiss federal acts and ordinances are not protected by copyright (Art. 5 Abs. 1 Bst. a URG, SR 231.1). Only the versions published by the Federal Chancellery on Fedlex are official. - **EU law** — © European Union, https://eur-lex.europa.eu. Reuse is authorised provided the source is acknowledged (Commission Decision 2011/833/EU). Only the texts published in the Official Journal of the European Union are authentic. - **FATF** — The FATF Recommendations © FATF/OECD. They are quoted here for reference, with attribution; the official text is on the FATF website (fatf-gafi.org). - **VSB 20** — © Swiss Bankers Association. The map summarises VSB 20 and does not reproduce its text. - The descriptions, notes and structure of the map are the author's own work.