On 1 October 2026, the Federal Act on the Transparency of Legal Entities (TJPG) and the new obligations for advisers under the Anti-Money Laundering Act (AMLA) enter into force. For single family offices, the decisive question now is which company, which activity and which responsible person is covered. A documented legal assessment and, where possible, a formal ruling by the authorities provide a sound basis for decision-making.[1]

The economic significance is considerable: the University of St. Gallen (HSG) estimates the Swiss SFO landscape at around 300 organisations, with associated family wealth, including businesses, of CHF 785 billion. 41 per cent of the 82 SFOs surveyed represent family wealth of more than one billion francs.[2]

Is a single family office exempt because it manages the family’s own wealth?

This must be assessed separately for each set of rules. The exemption under the Financial Institutions Act (FinIA) for the exclusive management of assets of persons with family or economic ties replaces neither the AMLA assessment nor the transparency register filing of a Swiss company limited by shares (AG). The label “single family office” does not in itself establish a general exemption.[3]

The final Anti-Money Laundering Ordinance (AMLO) expressly excludes “persons who provide services between group companies” from the definition of adviser. This is a key starting point for internal SFO structures. On the other hand, the official explanatory report mentions “family offices” as a possible setting for covered advisers, without distinguishing between single and multi family offices. The decisive question therefore remains whether the specific set-up falls under the group exemption. Family members personally, independent trustees, foundations and external fund vehicles cannot be attributed to a group merely on the basis of shared family interests.[4]

Where do the risks lie for international family structures?

In the activity: Professional involvement on behalf of third parties in certain financial transactions may be covered. This includes setting up non-operational Swiss legal entities and setting up foreign legal entities, even those with an operational purpose. Further connecting factors are the management of non-operational structures, their contributions and distributions, as well as certain real estate and equity transactions. Cross-checks are essential: for example, the exemption for certain family transactions, owner-occupied Swiss residential property, and transfers below CHF 5 million where the purchase price is settled in full through banks or other financial intermediaries subject to the AMLA.[5]

In the legal entity and staff: A Swiss SFO company (AG), a foreign fund, an LP, a trust and a foundation must each be classified individually. A foundation is in principle a legal entity; a trust is a legal relationship without legal personality of its own. Foreign legal entities may become subject to registration through effective management, a branch or ownership of real estate in Switzerland. For companies, the control threshold is in principle at least 25 per cent of the capital or voting rights; control in any other way is also sufficient. Trustees not subject to the AMLA have their own identification and documentation obligations under the TJPG; a blanket registration of every trust is not provided for. For staff, the employer, mandate relationships and their own functions as corporate officers must be examined. Not every employee has to join a self-regulatory organisation (SRO) personally.[6]

In the thresholds: An activity is in any event deemed professional if it generates more than CHF 50,000 in relevant gross annual revenue, involves more than 20 clients or transactions per year, concerns third-party assets exceeding CHF 5 million or has an annual transaction volume exceeding CHF 2 million. In addition, the general test of an independent activity aimed at generating ongoing income applies. These figures are not general thresholds for suspicious activity reports to MROS; such reports require the statutory conditions for suspicion to be met.[7]

Which authority can confirm non-subjection with binding effect?

SIF and Daniela Stoffel: The State Secretariat for International Finance prepared the reform at administrative level. The laws were adopted by the Federal Parliament; the Federal Council brings them into force and issues the implementing provisions. SIF can coordinate interpretive guidance, but it cannot create an SFO exemption through an FAQ that has no basis in the law.[8]

FOJ and FDF: The Federal Office of Justice, headed by Director Michael Schöll, maintains the transparency register. The Transparency Register Control Office is attached to the Legal Service of the Federal Department of Finance, headed by Simon Müller. It checks the substantive accuracy of entries and can order measures. Requests for clarification under register law must be addressed to the competent body depending on their subject matter.[9]

FINMA and SROs: For supervisory questions of subjection, FINMA, headed by Director Stefan Walter, is the central point of contact; its Asset Management and Markets division is led by Léonard Bôle. Affiliation with an SRO is decided by the self-regulatory organisation concerned. A clarification from FINMA does not replace a required register filing.[10]

MROS and Anton Brönnimann: The Money Laundering Reporting Office Switzerland at fedpol receives and analyses suspicious activity reports. It is not a general approval authority for SFO structures.[11]

For binding effect, the form of the decision matters. A legal opinion from a lawyer establishes the legal position; information from an authority documents that authority’s assessment. Where jurisdiction and a legitimate interest exist, an appealable declaratory ruling on the existence or non-existence of an obligation can be requested under Art. 25 of the Administrative Procedure Act (APA). It relates to the facts disclosed. There is no blanket “clean bill of health” that applies across all authorities.[12]

Which deadlines must family offices observe now?

No general three-month grace period. Advisers already covered on 1 October must comply with the relevant due diligence, organisational and reporting obligations from that date. The SRO application must be submitted by 1 December 2026; admission itself need not be completed by then. Until the decision, activity is limited to existing business relationships. Financial intermediaries that are already supervised must notify the competent supervisory authority of their additional advisory activity by the same date.[13]

In addition, for existing Swiss legal entities: the first commercial register change after 1 October triggers a one-month filing deadline, subject to the maximum deadlines below. The longer special deadline requires that all beneficial owners are already entered in the commercial register as shareholders or officers.[14]

¹ The earlier one-month deadline following the first commercial register change remains reserved. The month-end dates in the right-hand column are deliberately early filing targets. The obligation of financial intermediaries to report discrepancies in the register only begins six months after entry into force (Art. 54 TJPG).

A request for confirmation of non-subjection does not automatically suspend these statutory deadlines. Anyone who takes up a professional advisory activity at a later date must comply with the obligations immediately and, within two months, submit the SRO application or inform the competent supervisory authority (Art. 12g AMLO).

What are the consequences of getting it wrong?

Misjudgements can have criminal consequences. The TJPG provides for fines of up to CHF 500,000 for certain intentional breaches of reporting and disclosure obligations. Intentionally failing to file a suspicious activity report under the AMLA can likewise cost up to CHF 500,000, and a negligent failure up to CHF 150,000. Delegation does not remove the statutory responsibility for register filings. A legal opinion creates a documented basis but does not guarantee immunity from prosecution.[15]

For shared questions of interpretation, the Swiss Single Family Office Association in Zug, chaired by President Dr Kurt Moosmann and Vice-President Micha Blattmann, is an important point of contact. A binding clarification of an individual case must come from the competent authority and cover the specific family office and its actual scope of activities.[16]

Contact LINDEMANNLAW

LINDEMANNLAW offers structured clarification from a single source: we map the family and holding structure, including trusts, foundations, funds and LPs; prepare a legal opinion on register, FinIA and AMLA obligations; draft reasoned requests on subjection; where permissible, apply for a formal ruling of non-subjection; and translate the result into a deadline and responsibility plan. If the assessment reveals an obligation, we assist with the required filing or SRO affiliation.

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Sources

[1] Federal Council, press release of 12 June 2026, entry into force on 1 October 2026; exception for the provisions on official notaries, which enter into force later.

[2] University of St. Gallen, The Swiss Single Family Office Landscape 2026, pp. 8–9 and 13–17. Survey of 82 SFOs; figures on the overall SFO landscape are estimates or extrapolations.

[3] FinIA, Art. 2(2)(a); separately AMLA, Art. 2 and TJPG, Arts. 2–3.

[4] AMLO, Art. 2(3)(a); FDF, explanatory report on the TJPV, corrigendum of 11 August 2026, p. 54 (intra-group services) and p. 75 (reference to family offices). The group exemption does not cover service providers outside the group merely because the transaction is intra-group.

[5] AMLA, Art. 2(3bis)–(3ter) and (4ter), Art. 2a(6); AMLO, Arts. 12d–12f, each in the version of 1 October 2026.

[6] TJPG, Arts. 2–6, 9, 12 and 15–18; TJPV, in particular Arts. 1–6. Trusts and foundations require separate assessment according to legal form and Swiss connecting factor. On the distinction between trust and foundation: FOJ, explanatory report on the introduction of the trust of 12 January 2022, section 1.1.6.1. Arts. 15–16 TJPG concern trustees and cannot be applied to foundations across the board.

[7] AMLO, Art. 12f: para. 1 basic definition and alternative thresholds; paras. 3–4 special rule for related persons. AMLA, Art. 9(1ter) and (2) and Art. 14: suspicious activity reporting, professional secrecy and SRO affiliation are separate questions.

[8] SIF, State Secretary Daniela Stoffel; Federal Council, responsibilities and entry into force. On enforcement and delegation, see also Art. 41 AMLA and Art. 47 TJPG. Official position checked on the current SIF website on 21 September 2026.

[9] FOJ, Swiss transparency register; FOJ, current director profile Michael Schöll; FDF, Transparency Register Control Office; statutory tasks: TJPG, Arts. 33–39. On FDF responsibility: GS-FDF, current organisation chart; Federal Directory, Simon Müller, Head of Legal Service FDF. Personnel details checked on 21 September 2026. The Control Office is attached to this Legal Service; no separate section head is publicly named.

[10] FINMA, Executive Board; responsibilities and affiliation: AMLA, Arts. 12a, 14, 18 and 24–25. Affiliation is decided by the SRO. Official positions checked on 21 September 2026.

[11] Anton Brönnimann, Head of MROS, official presentation of 22 January 2026, pp. 1, 7–9 and 18; tasks and suspicious activity reports: AMLA, Arts. 9 and 23. The presentation is a fedpol/MROS document published by the conference organiser. Current official position: Federal Directory, Anton Brönnimann, Head of Division MROS, checked on 21 September 2026.

[12] APA, Art. 25: declaratory ruling by the authority competent in the matter where there is a legitimate interest. Scope and protection of legitimate expectations depend on the specific facts, the competent authority and the statutory requirements.

[13] TJPV, Annex no. 6, amendment of the AMLO, there “Transitional provision to the amendment of 26 September 2025”: application or notification by 1 December 2026, continuation within existing business relationships. For activities taken up later: AMLO, Art. 12g. On immediate obligations: FDF explanatory report, pp. 63–64.

[14] TJPG, Arts. 9–10 and 51–54. Art. 51(1): first commercial register entry with a change as an earlier trigger; paras. 2–3: maximum deadlines. The month-end dates given below are recommended planning dates, not an additional statutory transitional period.

[15] TJPG, Arts. 12 and 43–45; AMLA, Art. 37. In minor cases of negligent breach of the AMLA reporting obligation, prosecution and punishment are waived. Individual responsibility and fault must still be examined.

[16] Swiss Single Family Office Association, Board: Dr Kurt Moosmann, President; Micha Blattmann, Vice-President; Association address, Zug. Board positions checked on the association’s website on 21 September 2026.