Company setups and registered addresses: since 1 October 2026, the anti-money-laundering act covers advisers
Nothing on your desk changed on 1 October: the same holding companies, the same registered addresses, the same annual accounts. But since that morning, the law may call you an adviser. If it does, you must apply to a self-regulatory organisation before 1 December, and until it answers, you may only work within the client relationships you already have. How many of your files would pass its first look?
The short answer: since 1 October 2026, you are an adviser if you professionally take part, for clients, in the financial transactions around setting up non-operating companies in Switzerland or any company abroad, running them, paying money into or out of them, or buying and selling real estate, or if you provide a registered address for more than six months. Advisers identify each client and the beneficial owner, record what the service is for, keep the file, train their team and report suspicions. The first deadline is 1 December; the new transparency register follows within three to six months. A local AI, on servers in Switzerland, Meow's or your own, can sort the files you already hold, so your team starts with the gaps.
Checked against the law on 30 September 2026
Are you an adviser now?
- 1 December 2026
Already advising on 1 October? Apply to a self-regulatory organisation before this date. Until it decides, you may only work within existing client relationships (AMLO, transitional provision).
- 20 clients
Or 20 transactions, CHF 50,000 in fees, CHF 5 million of client assets or CHF 2 million of transactions in a calendar year: any one of them makes the advice professional, even as a side business (AMLO art. 12f).
- 3 to 6 months
The latest an existing company has, from 1 October 2026, to report its beneficial owners to the new transparency register, unless all of them already appear in the commercial register. Its top officer stays responsible, even when you file (Transparency Act, arts. 12 and 51).
How to check where you stand
0 of 8 checked
Setups, registered addresses, board seats, bookkeeping, payments: the law looks at the activity, not at your firm's name.
Setups and administration count for non-operating entities, and board seats in operating ones are excluded. Decide each case and keep the evidence.
More than 20 clients or transactions, CHF 50,000 in fees, CHF 5 million of client assets or CHF 2 million of transactions in a year makes it professional.
Property and company transfers under CHF 5 million paid only through banks, family and inheritance matters, litigation work, notarisation alone.
Then report the adviser activity to your supervisor before 1 December, and keep advising existing clients, new mandates from them included. If not, apply to a self-regulatory organisation.
The self-regulatory organisation looks at your internal rules, your organisation and your reputation, and at those who run and own the firm (AMLA art. 14).
Who the client is, who the beneficial owner is, what the service is for, and a file an outsider could follow (AMLA arts. 7 and 8b).
For each Swiss company you administer: its deadline, the data it needs, and who signs it off.
Ticked them all? The kit turns this into work you can start this week: six situations answered, the eight checks for each client file, the rules to sort the files you already hold, and a plan to test AI on them. Get the kit
Adviser or not? Six situations
The kit answers six common situations. Two of them:
- A registered address for a client's holding, for a year
- Covered: a registered address or premises provided for more than six months (AMLA art. 2 para. 3ter).
- Setting up an operating company in Zurich
- Not on the list: setups count for non-operating entities in Switzerland and for any entity abroad (art. 2 para. 3bis let. b).
- Setting up a company in Luxembourg
- In the kit
- Four holding-company setups in a year
- In the kit
- A board seat in an operating company
- In the kit
- A building sold for CHF 3 million
- In the kit
What was already covered
Acting as an officer of a domiciliary company was already financial intermediation (AMLO art. 6). Where the same activity is both, the rules for financial intermediaries apply to it (AMLA art. 2b).
Where a local AI helps
Hundreds of entity files to sort before the dates: a local model reads register extracts, deeds and correspondence, proposes a classification with the page it rests on, and lists what is missing, while a person decides. The files hold passports and ownership chains, so they stay on servers in Switzerland, Meow's or your own.
Where does your firm stand?
The self-check takes two minutes and says which first step fits. Or talk it through in a free 15-minute call.
Book a free 15‑minute call
Pick a time that suits you and confirm it from your inbox. If the time no longer works on our side, you hear from us the same working day.
What happens in 15 minutes
- 0–5 min
Your situation
What AI should do for you, and what it must never see.
- 5–10 min
What's possible
Which tasks can run privately, roughly what it costs, and what should stay human.
- 10–15 min
The next step
A test on your own documents, an assessment, or nothing yet.
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