Switzerland's New Anti-Money Laundering Law: What It Means for Companies and Domicile Providers in Zug
In the second half of 2026, two groundbreaking laws will come into force in Switzerland: the revised Money Laundering Act (GwG) And the new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Persons (TJPG). Both laws were passed by the Federal Councils on September 26, 2025 and have far-reaching consequences — not only for financial intermediaries, but also for domiciles, consultants and the companies themselves.
In this article, we summarize the most important changes, show what companies and their consultants in Zug should pay particular attention to — and finally hire free compliance template pack available, which we have developed for our own implementation and which we are happy to share with the industry.
Sources: Federal Council/SIF (sif.admin.ch), MLL Meyerlustenberger Lachenal Froriep (mll-news.com), HÄRTING lawyers (hardening.ch), PwC Switzerland (pwc.ch), FATF (fatf-gafi.org), HSLU Economic Crime Blog (hub.hslu.ch)
Why now? International pressure
Since 1990, Switzerland has been a member of Financial Action Task Force (FATF), the international organization for combating money laundering and terrorist financing. As part of the 5th round of evaluations, Switzerland will 2026—2027 underwent a new country review.
Source: SIF — Financial Action Task Force; FATF — Switzerland
This audit is the central driver of legislation: The Federal Council wants to ensure that the new measures are in force in good time so that they can be taken into account in the FATF audit. The entry into force is therefore for the second half of 2026 planned — various sources, including SVIT Switzerland, name the July 1, 2026 as a likely date.
sources: Federal Council, media release 15.10.2025; SVIT Switzerland
The new transparency register (TJPG)
For the first time, the TJPG creates a central, federal transparency register for beneficial persons. It is managed by the Federal Department of Justice and Police (EJPD) and is not public accessible — only certain authorities and financial intermediaries have access
Source: PwC Switzerland — Transparency Register
Who does it affect?
The TJPG applies to all legal entities under Swiss private law, in particular:
- Joint stock companies (AG)
- Limited liability companies (GmbH)
- Cooperatives
- Collective investment vehicles
- Foundations and associations
In addition, there are also foreign legal entities includes who have their actual administration in Switzerland or own real estate in Switzerland.
Source: HÄRTING lawyers
What do companies need to do?
The obligations can be summarized in three steps:
- Identification and verification beneficial owners — with appropriate care and plausibility check (a “know your owner” principle)
- message to the transparency register — electronically via a central platform or the cantonal commercial register office
- Ongoing update when there are changes in the ownership or control structure
Anyone who, alone or together with third parties, is considered to be beneficial owner at least 25% of capital or votes a company owns or otherwise controls it.
Sources: MLL — Transparency Register; PwC Switzerland
Facilitation for SMEs
For companies with simple structures — in particular for single-person associations where the sole shareholder is also the only member of the board of directors — a simplified reporting procedure foreseen. Companies for which all beneficial owners have already been registered in the commercial register also receive a Transition period of two years.
Source: Hoop — New Transparency Act
Scope of those affected
According to federal estimates, around 500,000 legal entities affected by the new register in Switzerland, such as one million people with obligations to cooperate means.
Source: The National Economy — Planned Transparency Register
The revised Money Laundering Act (GwG)
In parallel with the transparency register, the Scope of the GwG extended. Until now, the GwG has primarily applied to financial intermediaries (banks, asset managers, trustees). So-called “Advisor” included, provided that they professionally participate in certain risky legal processes.
Which activities are newly included?
The revised AMLA covers in particular professional participation in:
- Transactions with non-operational legal entities (registered companies) — including their formation, establishment, management, administration as well as contributions and distributions
- real estate transactions — Purchase and sale of land, drastic charges and the transfer of participation rights to real estate companies
Source: MLL — consultants in focus
New due diligence requirements for consultants
Anyone who reports to the GwG as a consultant must fulfill the following obligations:
- Identifying customers and Identification of beneficial persons
- documentation the clarifications and findings
- Organizational measures in your own corporate structure for prevention
- Connection to a self-regulatory organization (SRO), which is recognized by FINMA and supervises compliance with obligations
Source: MLL — consultants in focus
What do “organizational measures” mean in concrete terms?
The law requires consultants to set up processes and systems in their corporate structure that actively prevent money laundering and terrorist financing. In practice, this means that employees must be trained, customer relationships and transactions must be checked against sanction lists, and compliance with these processes must be regularly checked and documented internally — so that the SRO can understand everything during its annual audit.
Protection of professional secrecy
The following applies to lawyers and notaries: Representation and advice in connection with court, criminal, administrative or arbitration proceedings remains excluded from the scope of the GwG. The protection of professional secrecy was expressly taken into account, in particular in reporting requirements and SRO controls.
Source: MLL — consultants in focus
New: Sanction compliance in the GwG
Another paradigm shift: The revised GwG anchored for the first time organizational obligations to prevent sanction violations under the Embargo Act. Financial intermediaries and new reporting advisors must take appropriate measures to prevent evasion and violations of sanctions. This will make the Convergence of AML and Sanctions Compliance Regulatory consolidation.
Source: HSLU Economic Crime Blog
What does this mean for domicile providers in Zug?
As an international business location, Zug is particularly affected. Many companies are domiciled here as registered companies — an area that is explicitly covered by the extended scope of the GwG.
The problem: Not all providers work equally carefully
There is a wide range of domicile providers in Zug — from professionally managed companies to providers who, at best, implement compliance requirements superficially. With the new GwG, the wheat will separate from the chaff:
- UBO identification becomes mandatory for all domiciled companies
- Certified copies of identity documents The beneficial persons must be present
- Annual SRO audits ensure that obligations are actually met
- Organizational measures Money laundering and sanctions prevention must be demonstrably implemented
For companies and their advisors (trustees, lawyers, notaries), it is therefore crucial, when choosing the domicile provider on its Compliance readiness and ability to respect.
What should you pay attention to?
When choosing a domicile provider, we recommend the following checkpoints:
- Is the provider connected to an SRO (or is he actively preparing for it)?
- Are UBO investigations carried out consistently — with certified documents, not just self-declarations?
- Is mail forwarded reliably and promptly, particularly when it comes to official correspondence?
- Are the documents securely stored at the company headquarters?
- Are there professional premises for general meetings, audit visits and client meetings?
Timeline and next steps
Sources: SIF; Federal Council media release; SVIT; FATF
Compliance templates: Free for the industry
In preparing for the new GWG requirements, we have a comprehensive Compliance template pack developed that covers the most important operational processes. Because we are convinced that professional compliance strengthens the entire industry, we provide these templates free of charge.
What is included in the package?
The package includes 7 ready-to-use PDF templates:
- Client onboarding checklist — Structured checklist for accepting new domicile clients with all GWG-relevant check points
- UBO statement — Form for declaring beneficial owners, including obligations and signature field
- Risk classification — Assessment form with country, customer and service risk for classification in low/medium/high
- Sanction screening protocol — Documentation of every audit against SECO, EU and PEP lists with proof of date
- Periodic review — Form for regular review of existing customer relationships
- training protocol — Documentation of employee training with topic checklist and list of participants
- Internal suspicion report — Confidential form for escalation in case of suspicion of money laundering, including reference to the prohibition of information
Request templates
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The templates serve as practical working aids. We recommend that you adapt them to your specific situation in consultation with your SRO or a specialist.
Conclusion
The new GwG and TJPG mark a regulatory change for Switzerland. For companies in Zug — and in particular for those who work with headquarters — this means concrete new obligations. The requirements are feasible, but they require preparation, care and the right partners.
At Office Group Zug, we are already actively preparing for the SRO exams and have developed the above templates for our own company. If you have any questions or would like to exchange ideas, we look forward to hearing from you.
Office Group Zug GmbH Untere Roostmatt 8 | Baarerstraße 38 | 6300 Zug hello@myoffices.ch | myoffices.ch
This article is for general information only and does not constitute legal, tax or business advice. The content is provided without guarantee of completeness or accuracy. In particular, legal frameworks may change after publication. To assess your specific situation, we recommend consulting a qualified specialist. Liability on the part of Office Group Zug GmbH is — to the extent permitted by law — excluded.