TITLE: Switzerland's Financial Market Supervisory Authority Publishes Supplementary Money Laundering Risk Analysis Guidance
BODY:
On June 4, 2026, the Swiss Financial Market Supervisory Authority (FINMA) published supplementary guidance on money laundering risk analysis, updating its Guidance 05/2023. The update reflects FINMA's review of risk analyses from over 30 banks inspected in spring 2023, as well as analyses from numerous other banks and Financial Institution Act (FinIA) institutions.
FINMA recognised progress made by financial institutions in defining risk tolerance and structuring risk analyses. The authority noted that some FinIA institutions are already applying aspects of Guidance 05/2023 by analogy, with the same methodological principles applicable to both banks and FinIA institutions, though the level of detail may vary given FinIA institutions generally face lower risks. However, FINMA identified areas requiring improvement. Some institutions lacked explicit exclusions of certain countries, client segments, services, and products, or their exclusions did not align sufficiently with their business model. Additionally, some institutions failed to apply methodological principles correctly when conducting risk analyses.
FINMA emphasised that money laundering risk analysis serves as a key strategic management tool for financial institutions, forming the basis of their risk management framework. The analysis defines risk tolerance and establishes binding guidelines for structuring, organising, and managing the anti-money laundering framework, ensuring resources, processes, and controls are designed with risk focus and that regulatory requirements are effectively met.
The supplementary guidance, designated as FINMA Guidance 04/2026, is available in German, French, Italian, and English on FINMA's website.