Transparency Register and the Anti-Money Laundering Act:

The forthcoming entry into force of the Federal Transparency Register and the revised Anti-Money Laundering Act (AMLA) marks a significant turning point for many organisations. Beyond the legal obligations and formal requirements that have already been widely discussed, these developments raise a key question for companies and their advisers: how can they prepare in a structured and effective manner, well in advance of the announced deadline?

This publication deliberately takes a different approach to previous ones. It does not revisit the legal framework or the obligations themselves, but focuses on anticipating, organising and the practical implementation of these new requirements. The aim is to help organisations transform a regulatory constraint into a well-managed project, aligned with their governance and business activities.

 See also:

• The transparency register and its implications for companies and their shareholders (article published in April)
• The transparency register and the revised Anti-Money Laundering Act: new due diligence obligations for auditors and advisers (article 2 in the series, published in June)

Why planning ahead has become essential

Avoiding a reactive and fragmented approach

Experience shows that new regulatory obligations often lead to a rushed compliance phase, characterised by fragmented approaches, pressure on teams and an increased risk of errors or inconsistencies. The transparency register and the revised Anti-Money Laundering Act will be no exception.

Planning ahead, on the other hand, allows these changes to be transformed into a structured project, planned and aligned with the company’s operational realities. This is all the more important given that information relating to beneficial owners and high-risk activities is long-term in nature and must be updated regularly.

A cross-functional issue, not purely legal

Preparation is not solely a legal or tax matter. It concerns governance, internal processes, roles and responsibilities, as well as coordination between several key functions within the organisation.

Mapping structures and activities

A comprehensive overview as a starting point

Before any implementation, it is essential for companies to have a clear overview of their structures and activities. This involves, in particular:

• identifying the group’s entities, both in Switzerland and abroad;
• identifying structures that are potentially complex or non-operational;
• understanding existing control and governance flows.

This mapping forms the basis for all subsequent steps, both for the transparency register and for the due diligence obligations under the Anti-Money Laundering Act (AMLA).

Identifying sensitive areas

Certain structures warrant particular attention, for example:

•  international groups with multiple levels of ownership;
• property entities or holding companies;
• situations where certain individuals hold multiple roles (shareholder, board member, adviser).

The aim at this stage is not to make a legal assessment of these situations, but to identify areas of complexity so that they can be addressed as a priority.

Organising preparations within the organisation

Clarifying roles and responsibilities

Effective preparation relies on a clear definition of roles:

• who is leading the project at an operational level;
• which functions are involved (management, finance, legal, compliance);
• what is the role of the board of directors as a supervisory body.

This clarification helps to avoid overlaps, grey areas and decisions taken without a holistic view.

Integrating the issue into existing governance

Rather than creating parallel processes, it is often preferable to integrate the new requirements into the governance and control mechanisms already in place. This facilitates consistency of information and enhances the traceability of decisions.

From compliance to consistency over time

Ensuring the reliability and timeliness of information

The transparency register and due diligence obligations depend on the quality of the available information. Once the data has been collected, the challenge is to ensure its consistency over time, particularly during:

• changes in shareholding;
• restructuring;
• transactions or internal reorganisation

Establishing validation and updating processes from the outset significantly reduces the risk of subsequent non-compliance.

Anticipating interactions with other business issues

Information relating to the transparency of beneficial owners is increasingly being used in a variety of contexts: banking relationships, financing operations, transactions, or regulatory audits. Preparing in advance facilitates these exchanges and strengthens the organisation’s credibility.

The most common organisational errors

Without going into detail about legal obligations, certain practical difficulties recur regularly:

• underestimating the scope of the issue and postponing preparations;
• treating the transparency register as a mere administrative formality;
• working in silos, without coordination between the relevant functions;
• neglecting to document analyses and decisions.

A structured approach from the outset helps to avoid these pitfalls and tackle the new requirements with greater confidence.

How RSM Switzerland supports this preparation phase

The planning and implementation phase is an ideal area for cross-functional support.

An interdisciplinary approach

Thanks to the expertise of its Tax teams, RSM Switzerland is able to support organisations in:

• structuring their preparation process;
• identifying areas of complexity;
• aligning regulatory obligations, governance and operational activities.

Ensuring security without adding unnecessary complexity

The aim is not to multiply procedures, but to put in place proportionate processes, tailored to the size, structure and risk profile of each organisation.

Proactive support

By getting involved well in advance of the regulations coming into force, RSM Switzerland helps companies and their governing bodies to approach these changes with a long-term vision, whilst minimising operational and reputational risks.

Conclusion

The transparency register and the revised Anti-Money Laundering Act (AMLA) should not be viewed solely as new regulatory constraints. For organisations that plan ahead for their implementation, they represent an opportunity to strengthen the consistency of their governance, the reliability of their information and the quality of their internal processes. Structured preparation, undertaken early enough, is a key factor in approaching the entry into force scheduled for 2026 with confidence and control.