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On June 4, 2026, the Swiss Financial Market Supervisory Authority (FINMA) published a supplementary supervisory notice updating its anti-money laundering risk analysis guidance. The update supplements FINMA's supervisory notice 05/2023 with additional observations and experiences for both banks and financial institutions regulated under the Financial Institutions Act (FINIG-Institute). FINMA reviewed money laundering risk analyses from over 30 banks initially examined in spring 2023, alongside analyses from numerous additional banks and FINIG-Institutes. The authority identified progress in how institutions define their risk tolerance and structure their risk analyses. FINIG-Institutes have begun applying aspects of the 2023 guidance appropriately, though the methodological principles for creating risk analyses apply equally to both banks and FINIG-Institutes, with depth of detail varying based on institutional risk profiles. However, FINMA identified further improvement opportunities for both categories of institution. Deficiencies included missing or inadequate explicit exclusions of specific countries, customer segments, services, and products that do not align with institutional business models. Additionally, institutions demonstrated incorrect application of methodological principles underlying risk analysis creation. FINMA emphasises that anti-money laundering risk analysis serves as a central strategic instrument for financial institutions, establishing the foundation for risk management. It defines risk tolerance and establishes binding parameters for structuring, organising, and continuously managing anti-money laundering frameworks, ensuring resources, processes, and controls are risk-oriented and regulatory requirements are effectively met. The supplementary notice 04/2026 is available in German, French, Italian, and English, and applies to all supervised financial institutions under Article 25(2) of FINMA's anti-money laundering ordinance.

On June 4, 2026, the Swiss Financial Market Supervisory Authority (FINMA) published Supplementary FINMA Guidance 04/2026, updating its anti-money laundering risk analysis guidance. The update supplements FINMA's Guidance 05/2023 concerning the money laundering risk analysis pursuant to Article 25(2) AMLO-FINMA, with additional observations and experiences and clarifies Guidance 05/2023 with regard to banks and institutions licensed under the Financial Institutions Act (FinIA institutions). FINMA reviewed money laundering risk analyses from more than 30 banks initially examined in Spring 2023, alongside analyses from numerous additional banks and FINIG-Institutes. FINMA identified further room for improvement at both banks and FinIA institutions, so that risk analysis can serve as an even more effective key control and management tool for combating money laundering. The supplementary guidance presents the findings obtained since the release of Guidance 05/2023 and is based on the observations set out in said guidance, focusing on: Money laundering risk tolerance, detailing: The definition of risk tolerance. The ‘exception to policy’ process. The key risk indicators. The definition of risk tolerance. The ‘exception to policy’ process. The key risk indicators. Money laundering risk analysis, detailing: The money laundering risks to be considered. The implementation of the requirements according to Article 13(2bis) of the FINMA Money Laundering Ordinance (AMLO-FINMA) The monitoring of compliance with the business strategy and risk policy. The money laundering risks to be considered. The implementation of the requirements according to Article 13(2bis) of the FINMA Money Laundering Ordinance (AMLO-FINMA) The monitoring of compliance with the business strategy and risk policy. FINMA emphasises that anti-money laundering risk analysis serves as a central strategic instrument for financial institutions, establishing the foundation for risk management. It defines risk tolerance and establishes binding parameters for structuring, organising and continuously managing anti-money laundering frameworks, ensuring resources, processes and controls are risk-oriented, and regulatory requirements are effectively met. The observations and findings set out in the guidance may be applied by analogy to FinIA institutions and must be implemented taking into account an institution’s actual risk exposure.

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Switzerland's Financial Market Supervisory Authority Publishes Supplementary Anti-Money Laundering Risk Analysis Guidance

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Swiss Financial Market Supervisory Authority Publishes Supplementary Anti-Money Laundering Risk Analysis Guidance