UBO / Beneficial Owner Declaration
Collect and document the Ultimate Beneficial Owner (UBO) declaration for Swiss AML compliance. Captures controlling persons, ownership percentage, citizenship, PEP status, and signature per Swiss GwG Art. 4 and FATF Recommendation 24.
About this template
The UBO / Beneficial Owner Declaration form enables Swiss financial intermediaries, law firms, notaries, and regulated businesses to collect and document the identity of the ultimate beneficial owner (wirtschaftlich Berechtigter) in compliance with the Swiss Federal Act on Combating Money Laundering and Terrorist Financing (GwG / AMLA) Article 4, as well as FATF Recommendation 24. It captures all controlling persons, their ownership percentage, citizenships, domicile, politically exposed person (PEP) status, and an executed declaration with e-signature.
- Full identity and contact details of each beneficial owner
- Ownership or control percentage per person
- Citizenship and country of domicile for each UBO
- Nature of control: direct ownership, indirect control, or senior managing official
- Politically Exposed Person (PEP) status and relationship
- Source of funds declaration
- Document upload for identification documents
- Signed declaration confirming accuracy and completeness
Legal obligation — GwG Art. 4 and FATF Rec. 24
Financial intermediaries subject to the Swiss GwG (banks, securities dealers, asset managers, insurance intermediaries, lawyers, notaries, and trustees in scope) are legally obliged to identify and verify the identity of the beneficial owner before or at the time of entering into a business relationship. Failure to comply can result in criminal prosecution and loss of authorisation.
How to use this template
Open the template
Click 'Use template' to create a copy in your dashboard.
Configure for your entity type
Adjust the ownership structure sections to reflect whether the subject is a corporation, trust, foundation, or partnership.
Add your compliance reference
Insert your institution's AML policy reference number and the name of the responsible compliance officer in the form settings.
Set up document upload
Ensure the identity document upload field accepts certified copies of passport or national ID as required by FINMA Circular 2016/7.
Restrict access
Limit form response access to compliance and onboarding staff with appropriate data access controls.
Archive per GwG requirements
Store completed declarations for a minimum of 10 years after the end of the business relationship, as required by GwG Art. 7.
UBO identification in Swiss AML compliance
Switzerland's anti-money laundering framework is among the most comprehensive in the world, underpinned by the Federal Act on Combating Money Laundering and Terrorist Financing (GwG), FINMA Circular 2011/1 (Video and online identification), FINMA Circular 2016/7 (Video identification), and the Swiss Federal Banking Act. The cornerstone obligation for all covered financial intermediaries is the identification and verification of the beneficial owner — the natural person(s) who ultimately owns or controls the customer entity or on whose behalf a transaction is being conducted.
Who qualifies as a beneficial owner under Swiss GwG?
Under GwG Art. 2a and Art. 4, the beneficial owner is typically the natural person(s) who, directly or indirectly, holds 25% or more of the capital or voting rights of a legal entity, or who otherwise exercises control. Where no natural person meets this threshold — as is sometimes the case with complex holding structures — the senior managing official must be identified in their capacity as control person. For trusts and foundations, the settlor, trustee, protector, and beneficiaries (or class of beneficiaries) must all be identified.
PEP screening and enhanced due diligence
A beneficial owner who is a Politically Exposed Person (PEP) — a current or former senior government official, judicial officer, military officer, senior executive of a state-owned enterprise, or an immediate family member or close associate of such a person — triggers Enhanced Due Diligence (EDD) requirements. Swiss institutions must apply heightened scrutiny to the source of wealth and funds, obtain senior management approval, and conduct more frequent ongoing monitoring of PEP relationships.
The VSB 20 and FINMA expectations
For Swiss banks, the Agreement on the Swiss banks' code of conduct with regard to the exercise of due diligence (CDB / VSB 20), issued by the Swiss Bankers Association (SBA), provides detailed operational guidance on when and how to identify the beneficial owner. The VSB 20 supplements the GwG and sets out standardised forms (A, K, S, T) for documenting UBO declarations. Digital equivalents of these forms, with equivalent legal weight when signed with a qualified electronic signature, are increasingly accepted.
Frequently asked questions
What is the retention period for UBO declarations?
GwG Art. 7 requires financial intermediaries to retain all documents and records relating to customer due diligence, including UBO declarations and supporting identification documents, for a minimum of 10 years after the end of the business relationship or after a transaction has been executed. Records must be kept in a way that allows them to be presented to MROS (Money Reporting Office Switzerland) or law enforcement without undue delay.
Can a legal person be the beneficial owner?
No. The beneficial owner is always a natural person (a human being). If a legal entity such as a holding company is an intermediate owner, the financial intermediary must look through that entity to identify the controlling natural person(s) at the top of the ownership chain.
What happens if the beneficial owner cannot be identified?
If, despite all reasonable measures, the beneficial owner cannot be identified — for example in the case of widely held listed companies or certain trust structures — the financial intermediary must document the steps taken, apply risk-based enhanced monitoring, and in certain cases file a suspicious activity report with MROS or decline to enter the business relationship.