On 1 January 2016, the revised Agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence (CDB 16) will come into effect. A revision of the former agreement from 2008 has become necessary due to the recently introduced broad revisions to anti-money laundering regulations (see CapLaw-2015-31). The CDB 16 provides new and revised due diligence obligations for Swiss banks with regard to anti-money laundering and counter-terrorist financing. The revisions mainly focus on (1) the introduction of the concept of controlling persons for operating legal entities and partnerships, (2) new or revised template declaration forms as appendices to the CDB 16, and (3) a fundamentally revised framework and formal structure of the CDB 16.

By Robin Hauser (Reference: CapLaw-2015-60)