Money Laundering: Switzerland Publishes Its Third National Risk Assessment
Switzerland’s third National Risk Assessment provides an updated analysis of money laundering and terrorist financing risks, including vulnerabilities associated with international commodity trading.
On October 14, 2026, Switzerland’s third National Risk Assessment (NRA) was published by the Interdepartmental Coordinating Group on Combating Money Laundering and the Financing of Terrorism (CGMF). The Federal Council was briefed on the report at its meeting on the same day.
The official report builds on the previous assessments conducted in 2015 and 2021, examining the main threats, vulnerabilities within Switzerland’s economic and financial system, and the effectiveness of existing preventive and control measures. The overall risk landscape remains largely stable, despite emerging vulnerabilities associated with cryptocurrencies, financial technology, and geopolitical developments. Switzerland’s structural exposure to money laundering risk remains high, with organized crime, corruption, and property and tax crimes continuing to represent the main categories of predicate offenses. The report also examines risks associated with international commodity trading, with particular attention to trade finance activities.
Commodity Trading in the Risk Assessment
The report acknowledges the economic significance of Switzerland’s commodity trading sector, which encompasses not only trading activities but also related services such as logistics, trade finance, inspection, and quality control. According to figures from the Swiss Federal Statistical Office cited in the report, the sector comprises approximately 950 companies employing more than 10,000 people and generated an estimated CHF 19.2 billion in value added in 2024, representing 2.3% of Switzerland’s total economic value added. The international nature of these activities, the complexity of supply chains, and the involvement of multiple counterparties across different jurisdictions are relevant factors in assessing the associated risks.
With regard to commodity trade finance, the report identifies heightened inherent money laundering risks. Key contributing factors include the sourcing of a significant share of commodities from countries with elevated corruption risks, reliance on state-owned or state-linked enterprises, and the need for government-issued authorizations or licenses. These factors may increase the exposure of transactions to corruption risks, making counterparty identification, an understanding of transaction structures, and verification of supporting documentation particularly important.
Trade-Based Money Laundering and Risk Mitigation Measures
The report also addresses vulnerabilities associated with trade-based money laundering (TBML), which involves using commercial transactions to conceal or transfer illicit funds. Methods through which trade transactions may be exploited for money laundering include over- or under-invoicing of goods, fictitious shipments, multiple invoicing, and misrepresentation of goods.
The report distinguishes between inherent risk, arising from the characteristics of transactions, and residual risk, assessed after taking existing preventive and mitigating measures into account. It also acknowledges the expertise of commercial banks in trade finance, including specialized personnel, dedicated desks, and specific control mechanisms, alongside supervision by the Swiss Financial Market Supervisory Authority (FINMA). Taking these measures into account, the residual money laundering and terrorist financing risk for commercial banks as a whole is assessed as medium.
Regulatory Implications
The report does not make specific recommendations to introduce additional anti-money laundering requirements for commodity trading companies, nor does it propose extending the scope of the Swiss Anti-Money Laundering Act (AMLA) to the sector as a whole. More broadly, however, it emphasizes the importance of reviewing the adequacy of the legislation’s scope to prevent higher-risk activities from shifting to less regulated areas. Its recommendations focus primarily on strengthening the effectiveness of the prevention and supervisory framework, improving information sharing, and assessing the adequacy of existing regulatory instruments.
Regarding precious metals, Recommendation 8 calls for a review of the Precious Metals Control Act and its implementing ordinance to assess their efficiency and effectiveness, with legislative amendments to be considered if necessary. This is a recommendation for regulatory review, not an amendment that has already been adopted. The report also assesses the residual risk as medium for both regulated precious metals trading and the purchase of used precious metals, highlighting challenges in tracing the origin of the latter.
Implications for the Sector
For commodity trading, the report highlights risks associated with financing international transactions while acknowledging the role of risk controls implemented by specialized financial intermediaries. While it does not recommend introducing new anti-money laundering requirements specifically for the sector, it calls for a review of the legislation governing precious metals control, also in light of the challenges associated with tracing the origin of used precious metals.