Switzerland adopted two major pieces of AML legislation in September 2025: the Legal Entities Transparency Act (LETRA, also referred to as LETA) and a revised AMLA extending due diligence obligations to lawyers and notaries. Both are expected to enter into force around mid-2026, timed to Switzerland's next FATF mutual evaluation in 2027. For Swiss IAMs, the most significant change is the introduction of a central federal Transparency Register of beneficial ownership information — but the Form A obligation remains unchanged.
What is LETRA / LETA?
LETRA (Bundesgesetz über die Transparenz juristischer Personen und die Identifikation der wirtschaftlich Berechtigten) was adopted by the Swiss Parliament on 26 September 2025. Its full name in English is the Legal Entities Transparency Act; it is also abbreviated LETA in English-language materials.
LETRA creates a central federal Transparency Register of beneficial owners for Swiss legal entities, administered by the Federal Office of Justice (FOJ). This is Switzerland's response to longstanding FATF criticism regarding the absence of a central UBO register and the limitations of the Form A/K process as a purely intermediary-held record.
Entry into force: Expected around mid-2026. The exact date is linked to implementation readiness and the proximity of the 2027 FATF evaluation.
Which entities are in scope?
LETRA applies to Swiss legal entities that must identify and register their beneficial owners:
- AG (Aktiengesellschaft)
- GmbH (Gesellschaft mit beschränkter Haftung)
- Cooperatives
- SICAV and SICAF (collective investment vehicles)
- Limited partnerships for collective investments
Cross-border scope — certain foreign entities with a Swiss nexus are also in scope:
- Branch offices registered in Switzerland
- Entities with effective management in Switzerland
- Entities holding Swiss real estate
Entities that are already subject to equivalent transparency obligations (FINMA-supervised entities, listed companies) are partially exempt from registration requirements.
Who can access the Transparency Register?
Access is restricted — this is one of the most important features of LETRA for compliance professionals to understand.
Who can access:
- Swiss regulatory authorities (FINMA, cantonal authorities, tax authorities, MROS, intelligence services)
- Swiss-regulated financial intermediaries conducting KYC and due diligence
Who cannot access:
- The general public — public access was explicitly rejected by Parliament
- Foreign compliance teams with no Swiss regulated presence do not have direct right of access
- Journalists and civil society organisations do not have access
This is significantly more restrictive than some EU member states' UBO registers, which have been or were required to be publicly accessible. Switzerland chose a restricted-access model.
Does LETRA replace the Form A obligation?
No. This is the single most important point for Swiss IAMs.
LETRA introduces a central Transparency Register but does not replace the Form A requirement. Financial intermediaries must continue to:
- Obtain beneficial ownership declarations directly from clients (Form A and/or Form K)
- Conduct their own plausibility verification of those declarations
- Retain the declarations for ten years under AMLA Article 7
The Transparency Register is an additional verification resource — intermediaries will be able to query it as part of the plausibility check. It does not carry the presumption of accuracy afforded to public registers like the Handelsregister. Discrepancies between the register and an intermediary's own findings must be reported to the FOJ.
In practice: the Form A workflow remains the same; the register adds a cross-check step.
The revised AMLA: lawyers and notaries
The revised AMLA, adopted simultaneously with LETRA and expected to enter force around mid-2026, extends AMLA due diligence obligations to "advisors" — primarily lawyers and notaries.
In scope under the revised AMLA:
- Lawyers and notaries who assist in transactions involving non-operational legal entities (domiciliary companies, holding structures, similar structures)
- In-scope activities: formation, administration, or transfer of such entities; nominee directorship arrangements; provision of registered address
What in-scope advisors must do:
- Verify client identity
- Identify beneficial owners
- Establish an internal compliance framework
- Join a FINMA-recognised SRO
Explicitly excluded: Transactions involving operational companies — lawyers advising on commercial contracts, M&A of operational businesses, and similar engagements are out of scope. The revised AMLA targets advisors who facilitate the formation and use of domiciliary structures.
Switzerland's FATF context
Switzerland is a member of FATF and subject to periodic mutual evaluations. The most recent evaluation identified deficiencies in:
- Due diligence controls (Recommendations 22 and 23) — covering designated non-financial businesses and professions (DNFBPs) including lawyers and notaries
- Oversight of professional enablers
The LETRA/AMLA reform package directly addresses these findings. The mid-2026 entry-into-force target is designed to ensure the legislation is operational before Switzerland's next FATF evaluation in 2027, which will assess whether the deficiencies identified in the previous evaluation have been remediated.
Switzerland's current FATF status: Switzerland is a FATF member in good standing — it is not on the FATF grey list or black list. The reforms are preventive and aimed at maintaining that status through the 2027 evaluation.
What IAMs should do to prepare
Before mid-2026:
- Review your Form A documentation process — ensure forms are compliant and plausibility checks are documented
- Confirm your SHAB monitoring is systematic and UID-based — this does not change under LETRA
- Brief your compliance team on the Transparency Register — understand what it is, who can access it, and how it will integrate with your existing Form A workflow
- Check if any of your clients may be newly in-scope for LETRA registration obligations
After LETRA enters force:
- Incorporate a Transparency Register query into your Form A plausibility check for in-scope Swiss entities
- Document any discrepancies between the register and client declarations and report to the FOJ as required
- Update your compliance documentation to reflect the new verification step
Key terms
| Term | Definition |
|---|---|
| LETRA / LETA | Legal Entities Transparency Act — adopted September 2025, entry into force ~mid-2026 |
| Transparency Register | Central federal UBO register administered by the Federal Office of Justice |
| FOJ | Federal Office of Justice — administers the Transparency Register |
| Form A | Declaration of beneficial owner — remains mandatory under LETRA |
| FATF | Financial Action Task Force — evaluates Switzerland's AML framework in 2027 |
| AMLA | Anti-Money Laundering Act — core Swiss AML statute, revised September 2025 |
| DNFBP | Designated Non-Financial Businesses and Professions — includes lawyers, notaries |
| MROS | Money Laundering Reporting Office Switzerland |