Swiss financial regulation becomes a critical stage in 2025, when the lawmakers are considering new sources of funds to increase supervision. The core of this change is represented by a proposal to adopt a fee-based compliance model, which would directly fund the Money laundering reporting office Switzerland (MROS) enabling it to react better to the growing workloads.
The federal government of Switzerland has committed to provide comprehensive options by the year-end in a bid to combat the increased number of suspicious activity reports (SARs) and complex nature of financial crime. This would shift the funding of oversight to specific taxes on the regulated themselves. It is timed when more strict enforcement has been implemented with over CHF 100 million in fines being handed out since the beginning of 2024 itself evidently pointing at a shift in the national stance on anti-money laundering (AML) measures.
Political Momentum And International Alignment
The urge to have a sustainable funding framework is in line with the renewed undertakings as per the updated Anti-Money laundering Act (AMLA) and the increasing pressure exerted by the international community such as the Financial Action Task Force (FATF). The most recent FATF mutual evaluation called on the Swiss government to ensure that its ambitious changes in law are accompanied by equally robust implementation capacity and financial resources.
At the same time, the launch of a central register of ultimate beneficial ownership (UBO)—covering more than 600,000 corporate structures—highlights the scope of reform and the increased need for monitoring staff, digital tools, and analytical infrastructure.
Impacts Of Fee-Based Models On Agency Resources And Compliance
Fee-based compliance is expected to enable MROS to scale its operations efficiently, offering greater flexibility in recruiting experts, investing in artificial intelligence for pattern detection, and supporting quicker follow-ups on financial red flags. This added capacity is not just a technical requirement, it reflects a policy objective to hold the financial sector more accountable for its compliance role.
With regulators aiming to shift cost burdens closer to the origin of risk, fee-based funding is framed as a market correction. By linking fees to the volume or type of regulated activities, the system could incentivize more robust internal controls among banks, asset managers, and fiduciaries. Swiss Finance Minister Karin Keller-Sutter has reinforced this vision, stating that strengthening AML supervision is “imperative for national credibility and future competitiveness.”
Operational Benefits And Risk-Based Scaling
Agencies anticipate that fee-based revenue streams will allow real-time adjustments to AML operations as financial risks evolve. Unlike static annual budgets, fee-derived funding can support modular investment in urgent capacities such as cybercrime detection or cross-border transaction tracking without waiting for parliamentary appropriations. This agility is seen as increasingly vital given the transnational nature of financial misconduct.
Stakeholder Concerns And Debates On Competitiveness
Despite broad regulatory support, the fee-based model has generated unease within financial institutions and business-friendly political blocs. Critics argue that new compliance costs could undermine Switzerland’s attractiveness as a global wealth management hub, especially when competing with jurisdictions such as Singapore or Dubai that promote lighter regulatory touchpoints.
Parliamentarians from the Swiss People’s Party, Centre Party, and Liberal Party have raised concerns about compliance overreach and the potential market exit of smaller players. Liberal Party MP Simone Gianini remarked that “transparency goals must not result in overregulation,” warning that excessive levies could stifle innovation and reduce service diversity.
Industry Resistance And Cost Distribution
Industry groups emphasize that the current regulatory environment already imposes substantial costs on firms, particularly those with smaller operations or specialized clientele. They worry that indiscriminate fee models could disproportionately burden low-risk entities or create incentives to offload clients deemed too costly to monitor.
Nevertheless, government estimates suggest that over 97 percent of firms subject to AML obligations would be minimally affected, especially if a tiered fee structure is adopted. Supporters argue that the reputational benefits of enhanced oversight far outweigh the temporary disruption.
Practical Outcomes And Future Trajectories
Experiences in the European Union and United Kingdom suggest that fee-based models can significantly improve the operational effectiveness of financial intelligence units. In the UK, for instance, increased funding helped clear backlogs in suspicious activity report reviews and expand enforcement reach. Swiss authorities are studying such models as they prepare final legislation for parliamentary review in 2026.
Switzerland has already seen improved enforcement outcomes in 2025. In February, FINMA imposed a CHF 1 million fine on Morgan Stanley for AML breaches, citing failure to maintain adequate controls over cross-border transactions. This case, alongside others, illustrates the government’s willingness to hold both institutions and individual compliance officers accountable under Article 29 of AMLA and FINMA Circular 2017/1.
Data Integration And Long-Term Monitoring
Other than headline fines, regulators have shifted their focus to system-level changes. Enhanced data-sharing deals with EU officials, further development of machine learning software to identify risks, proactive analysis of the onboarding behavior, etc. is all aimed at making sure that fee-based compliance becomes a quantifiable result. However, long-term evaluations would be required to help in finding out whether these models pervert market structure or deter financial innovation.
Balancing Innovation, Integrity, And Oversight
The overall question that the Swiss regulators will be asking in 2025 is whether the introduction of fee-based compliance could work as a stimulus towards sustainable financial governance or it could be another layer of bureaucracy. Decision makers will have to strike a balance between proactive enforcement and the economic reality of a competitive financial sector that will be operating in a variety of legal jurisdictions.
The fee system structure will be of major importance. Being designed with transparency, risk-scaled, and clear reporting requirements would allow increasing the level of trust among the population, as well as decreasing direct financial pressure on the state. However, when used disregardless or without sensitivity to the actualities of operations, it can speed up the process of consolidation and undermine the time-honored image of Switzerland as having financial independence and regulatory prudence.
The ultimate form of the AML strategy of Switzerland in 2025 will not be formed solely by internal forces, but also by changing global norms and market demands. The Swiss policymakers working on the fee-based model of MROS will determine the further stage of the fight against financial crime in Switzerland, as their success in creating specific, effective and fair compliance structures. The rewards are enormous, and the results may transform the manner in which the global financial system considers the balance between transparency and competitiveness.