Factors arousing suspicion

The Money Laundering Reporting Office Switzerland’s (MROS) annual report contains information about the factors arousing suspicion which lead to Suspicious Activity Reports (SARs). In 2016, 34% of the reports were based on information from the media, including data collections such as KYC records, which contain consolidated data from the media and internet (government websites). In the 2012 annual report (p.10), the MROS indicates that “the financial intermediary may submit a SAR [...] on account of a suspicion based on probability, doubt or a sense of unease about entering into a business relationship.”

The number of reports submitted voluntarily has risen continuously since 2010, and increased noticeably from 2013, after the MROS clarified its position in its 2012 annual report. We can therefore conclude that information from the media has become more important. The annual reports do not indicate whether the rate at which reports are being passed on to the criminal authorities has also risen.

Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

Eurospider Information Technology AG
Winterthurerstrasse 92
8006 Zürich