Enhanced due diligence requirements
The enhanced due diligence requirements are designed to prevent new untaxed monies being accepted in future. This is part of the financial centre strategy for ensuring a tax-compliant financial centre in Switzerland. Financial intermediaries should not accept any new untaxed monies and should review existing business relationships in terms of their tax compliancy.
Originally, it was proposed that the enhanced due diligence provisions be set down in the AMLA. However, the Federal Council has now decided to incorporate the provisions in the draft of the Financial Institutions Act and coordinate the timing with the introduction of the Automatic Exchange of Information (AEOI). As the AEOI is now planned to be the standard, the enhanced due diligence requirements should only apply to customers from countries in which the AEOI and FATCA are not applicable.
The consultations on the enhanced due diligence requirements were held from 27 February to 15 June 2013, and the consultations on FINIG were held from 25 June to 17 October 2014.