Third Risk Report: Where Switzerland Remains Vulnerable
Stable does not mean safe
The third national risk report on money laundering and terrorist financing is out. The Federal Council was informed of it on 14 October. Its core message sounds reassuring at first: Switzerland's risk exposure has overall not changed substantially. Anyone who concludes from this that the financial centre is out of danger is misreading the finding. A stable risk situation describes how things have developed over time – not the scale of a problem, and certainly not an all-clear.
Competence also deserves clarification. This is not a report by the Federal Office of Public Health, even if the announcement may technically appear on several federal portals. The analysis was prepared by the interdepartmental coordination group on combating money laundering, terrorist financing and proliferation financing, known as KGGT. In substance, the topic belongs to the financial centre and to cooperation between authorities, supervision and criminal prosecution.
Where the greatest dangers lie
The report states clearly where the greatest dangers lie. Money laundering is linked above all to organised crime, corruption and asset and tax crime. Such offences generate proceeds whose origin is to be concealed and which are then to be fed into the legal economic cycle. For Switzerland the international dimension is central: a large, closely interconnected financial centre can be attractive as a target, a transit point or a place of service in cross-border cases. This says nothing about the legality of ordinary international financial transactions; it is a statement about the risk that can arise from complex and international structures.
On terrorism the report draws a different line. In the KGGT's assessment, the risk of terrorist financing remains comparatively limited. The wording is deliberately precise. It does not mean that no threat exists, but that it is rated lower than the dominant money laundering risks. Precisely with rare but consequential events, prevention nevertheless has to work.
Newer technologies and geopolitical shifts are changing the baseline, even though the overall finding remains stable. The report points to elevated risks in areas with strong foreign entanglements, wide uptake of new technologies or still young regulation. This does not amount to blanket suspicion of individual sectors or customer groups. Risk-based action means that authorities and obliged companies look more closely where structure, product or business model can create heightened vulnerability.
Diagnosis alone is not enough
The report does not stop at diagnosis. The KGGT recommends providing supervisory and enforcement authorities with adequate resources, improving the data foundations and intensifying exchange among the actors involved. It also calls for examining whether the reporting system, precious metals controls and the new transparency register work effectively or need adjustment. That is decisive: a register and a reporting duty are not an end in themselves. They only help if the data are up to date, accessible to authorised bodies and usable in investigations.
The transparency register is especially topical here. It began operating on 1 October and is meant to make the beneficial owners of entities subject to reporting visible. The report does not simply demand further rules; it first asks for an assessment of whether the new instruments fulfil their purpose. In doing so it links control with the capacity to learn: in a field where perpetrators' methods change quickly, a rule once adopted cannot count as a final solution.
The risk analysis complements the national strategy to combat money laundering and terrorist financing adopted in March. That strategy relies among other things on prevention and supervision, criminal prosecution, the repatriation of assets acquired unlawfully, and the fight against terrorist financing. The new report supplies the situation assessment for this: it is meant to help decide where scarce resources, supervision and further legislative development should start first.
How the report will be measured
For Switzerland this yields a sober task. The report documents neither a sudden collapse in the integrity of the financial centre nor a success message suggesting that no adjustments are needed. It describes a permanently high and dynamic need for protection. The finding will only prove truly meaningful once it becomes clear whether data quality, cooperation, supervision and the new transparency instruments actually improve in day-to-day practice – also with a view to the forthcoming country review by the Financial Action Task Force in 2026 and 2027.
Sources
- Confederation/KGGT: Third national risk report on money laundering and terrorist financing, 14 October 2026
- FDF: Overview of the publication of the third risk report
- SIF: Integrity of the financial centre and mandate of the KGGT
- Swiss Transparency Register: start of operations on 1 October 2026
- Federal Council: National strategy to combat money laundering and terrorist financing, 20 March 2026
