Beneficial Ownership Registers 2025: Switzerland, Bermuda, Malta — Operational Shifts Every Trustee & Family Office CEO Must Implement

Oct 8

You’re stewarding wealth across jurisdictions rewriting their playbooks in real time.
Your beneficial-ownership workflows still rest on static assumptions — public registers, blanket access, generic attestations — while regulators now tighten verification and recalibrate access toward privacy-respecting, authority-led models.

Your counsel says “wait for ordinances.”
Your bankers demand faster attestations.
Your risk team wants one playbook that fits all.
None of that exists — yet.

Have you tried hiring another compliance consultant who delivers a 40-page memo but no executable system?
What about investing in an “AI-powered” KYC tool that still leaves your staff reconciling PDFs across three jurisdictions?
Or waiting for “clearer guidance,” only to watch deadlines compress while your team drowns in edge cases?

These approaches fail because the operating model itself is mis-sized.
The new era isn’t about more PDFs — it’s about governance primitives: verification, access control, and audit trails wired into your systems so you pass both effectiveness and privacy tests without friction.

Switzerland’s Non-Public Federal Beneficial Ownership Register — What Family Offices Must Operationalize Now

Switzerland has approved a central, non-public federal register operated by the Federal Office of Justice (FOJ). Access is limited to competent authorities, and financial intermediaries may rely on entries for AML diligence under conditions. Entry into force is expected no earlier than 2026 – 2027, subject to ordinances.

Thresholds: ≥25 % of capital/votes or control by other means, fallback to the senior managing official.
Impact: You cannot outsource KYC/UBO to the register. Identify, verify, and document evidence — regulators will cross-check your data against FOJ records.
Next step: Design workflows with configurable policy toggles for verification and privacy once ordinances issue.

Bermuda’s Beneficial Ownership Act 2025 — Verified Data and Registrar Oversight

The Beneficial Ownership Act 2025 (Royal Assent 28 Sept 2025) transfers the regime to the Registrar of Companies (RoC) and mandates verified identity data — nationality, date of birth, residential address, and government-ID details confirmed via reliable sources.

Access: Competent authorities and regulated entities may obtain data for due diligence with strict onward-use limits aligned to PIPA privacy principles.
Sanctions: Civil penalties up to BMD 250 000 per breach under the Compliance Measures Act 2017.
Company tools: Section 17 allows restriction of shares/interests for non-responsive BOs.
Effective date: Implementation expected on or around 3 Nov 2025 per Gazette and Conyers analysis.

Malta’s AMLD6 Legitimate-Interest Access — Legal Notice 127 of 2025 Breakdown

Malta amended its Companies Act (Register of BO) Regulations via Legal Notice 127 of 2025 to transpose AMLD6 Article 74.
Any person may access BO data if demonstrating a legitimate interest tied to preventing ML/TF; competent authorities retain free access.

Data changes: new statutory forms, multi-nationality capture, and Form BO2 for “extent/nature” updates only.
Trustees: Private trustees now in scope with administrative penalties.
Oversight: The MBR may consult bodies and must notify applicants, with judicial review available.

Why Your Past Approaches Fail

Document dumps ignore Data Security & Privacy — no purpose-bound access or retention control; exposure under PIPA-style regimes.
Generic KYC tools fail Integration — they don’t speak to your DMS/CRM; rekeying persists.
Waiting for regulation exposes Ethical & Regulatory Risk — no adaptive rules engine to adjust as ordinances drop.

What’s Converging

FATF-driven accuracy: Centralized, verified, evidence-backed BO data.
Privacy-respecting access: Authority-led and legitimate-interest gates replace public scraping.
Sanctions with teeth: From Switzerland’s penalties to Bermuda’s daily fines.
Open items: Deadlines and auditability still depend on secondary rules — build for change.

The Quiet Solution: FiduciaCorp

FiduciaCorp designs AI architecture that treats BO data as a structural asset — privacy-forward, audit-ready, seamlessly integrated.
We eliminate rekeying, align verification with FATF effectiveness, and embed legitimate-interest logic into your existing stack.

We resolve three strategic pain points:

Data Security & Privacy — purpose-bound access, retention controls, full auditability.
Integration with Existing Systems — API-level connectors to your CRM/DMS for zero-friction updates.
Ethical & Regulatory Risk — jurisdiction-aware rules that update as ordinances evolve.

You cannot afford to wait for the next ordinance drop.
If your BO workflows still rely on static attestations and manual reconciliation, you are structurally exposed.
DM us on LinkedIn or Instagram, or visit https://www.fiduciacorp.com/contact to map your jurisdiction stack and eliminate friction before the next audit cycle.

Selected Sources

Swiss Federal Council dispatch 2024; Lexology commentaries.
Bermuda Official Gazette 2025; Conyers BoA 2025 brief.
Malta Government Gazette L.N. 127/2025; MBR Circular Aug 2025.
CJEU Judgment C-37/20 & C-601/20 (2022).

Frédéric Sanz

With over 20 years of elite financial expertise in Switzerland, I specialize in managing UHNWIs assets, leading high-performing teams, and driving innovation in wealth management. As a TEP, MSc., MAS, and Executive MBA with AI diplomas from MIT and Kellogg, I combine deep technical knowledge with strategic leadership for business growth.

A blockchain specialist, I deliver exceptional revenue growth while elevating client satisfaction. Fluent in Spanish, French, Italian, and English, I offer a global perspective, blending advanced AI-driven strategies with traditional wealth management.