金融行动特别工作组-瑞士在加强打击洗钱和资助恐怖主义措施方面取得的进展（英）-2023.10-24页_1mb

Anti-Money Laundering and Counter-Terrorist Financing Measures in Switzerland Follow-up Report & Technical Compliance Re-Rating

October 2023

Introduction

This is the fourth enhanced follow-up report for Switzerland, adopted by the FATF Plenary in October 2023. It builds on the 2016 Mutual Evaluation Report (MER), which placed Switzerland under enhanced follow-up due to technical compliance shortcomings. The report analyzes progress in addressing these issues, particularly focusing on Recommendations 10 and 40, and provides updated technical compliance ratings.

Progress in Technical Compliance

Switzerland has made significant strides in improving technical compliance by remedying key deficiencies identified in the MER. Progress resulted in re-ratings:

• Recommendation 10: Upgraded from Partially Compliant (PC) to Largely Compliant (LC) due to improvements in customer due diligence, beneficial ownership verification, and risk-based approaches. Minor shortcomings remain, such as lack of explicit provisions for wire transfers and beneficial owner understanding.
• Recommendation 40: Upgraded from PC to LC due to enhancements in international cooperation mechanisms, including information sharing and feedback processes. Remaining gaps involve FINMA's client procedure and CFMJ's lack of practice in international cooperation.

Overall technical compliance was evaluated, with most recommendations upgraded. Switzerland now has three recommendations still rated PC and will move to regular monitoring.

Conclusion and Next Steps

Switzerland successfully addressed most technical compliance deficiencies, with R.10 and R.40 largely compliant. The country must continue improving implementation, and its progress will be reported in the next mutual evaluation (5th round).