Regulation Switzerland

Suspicious activity reports to MROS

Updated: 17 October 2026 · Leutrim Miftaraj, FLIORE · Editorial standards · Deutsche Fassung

Short answer

If a Swiss financial intermediary knows or has reasonable grounds to suspect that assets derive from a felony or aggravated tax offence or serve terrorist financing, it must report to the Money Laundering Reporting Office Switzerland (MROS) without delay (Art. 9 AMLA). For simple suspicion there is a right to report (Art. 305ter para. 2 Swiss Criminal Code). Reports are filed electronically via goAML; clients must not be informed.

Duty and right to report

The reporting duty under Art. 9 AMLA requires knowledge or a reasonable suspicion. A suspicion is reasonable where concrete indications exist that cannot be dispelled after additional clarifications. In addition, Art. 305ter para. 2 of the Swiss Criminal Code allows a report on observations indicating money laundering even without a reasonable suspicion. MROS is part of the Federal Office of Police (fedpol).

How a report proceeds

Document the anomaly and carry out additional clarifications under Art. 6 AMLA.
Assess the result: dispelled or reasonable suspicion.
File the report in the electronic system goAML with all relevant documents.
Document the report and the reasons for the decision internally.
Continue the relationship and review instructions carefully until MROS responds.

After the report

Prohibition of information: neither the client concerned nor third parties may be informed of the report (Art. 10a AMLA).
Freezing of assets: if MROS forwards the report to a prosecution authority, the financial intermediary freezes the assets concerned until that authority decides, for at most five working days (Art. 10 AMLA).
Termination: if MROS does not state within 40 working days of receiving the report that it is forwarding the information to a prosecution authority, the relationship may be terminated – only in a way that keeps the outflow of assets traceable, and MROS must be informed of the termination without delay (Art. 9b AMLA).
Exemption from liability: anyone reporting in good faith cannot be held liable for breaching confidentiality (Art. 11 AMLA).

Does this apply to my family office?

The reporting duty applies to financial intermediaries within the meaning of the AMLA. A single family office managing only the wealth of one family is, depending on its set-up, not subject to it; multi family offices, asset managers, trustees and fiduciaries acting as officers of domiciliary companies generally are. Family offices subject to the AMLA are affiliated with a self-regulatory organisation or supervised by FINMA.

Common mistakes

Reporting too late after long internal discussion, missing documentation of the clarifications, warning the client through conspicuous questions, or a hasty termination that obscures the trail. Cases not reported should also be documented with reasons – a later review will ask why no report was made.

In FLIORE

FLIORE records clarifications, evidence and decisions per mandate in the audit trail and flags anomalies from transactions and screening. The report itself is filed via goAML; the platform provides the structured documentation for it.

At a glance

Reporting office	MROS, Federal Office of Police (fedpol)
Duty	Knowledge or reasonable suspicion (Art. 9 AMLA)
Right	Simple suspicion (Art. 305ter para. 2 Swiss Criminal Code)
Channel	goAML (electronic)

Frequently asked questions

How quickly must a report be made?

Without delay once a reasonable suspicion exists after the clarifications. The clarifications themselves must not be dragged out.

May I continue to serve the client after the report?

Yes, the relationship generally continues. Instructions must be reviewed carefully, and the client must not be informed of the report.

What about aggravated tax offences?

Since 2016 they have been predicate offences to money laundering. Assets derived from an aggravated tax offence can therefore trigger a reporting duty.

Must a rejected client be reported?

The reporting duty also applies if negotiations to establish a relationship are broken off because of a reasonable suspicion.

Sources

This page provides orientation and does not replace legal or tax advice. The cited legal sources in their applicable version are authoritative.

ComplianceEnhanced due diligence in practice Regulation SwitzerlandSwiss Form A: establishing the beneficial owner Regulation SwitzerlandFATCA in Switzerland: what family offices need to know ComplianceThe risk-based approach in a family office