Underground Banking: Switzerland at the Crossroads Between Innovation and Systemic Weaknesses

Publication Date: Press ReleasePublished on November 21, 2025

Author: news.admin.ch / fedpol
Source: fedpol Press Release
Publication Date: November 21, 2025
Summary Reading Time: 4 minutes


Executive Summary

Switzerland positions itself as a coordination hub in the fight against informal financial systems with the second international Underground Banking Roundtable, yet reveals systemic weaknesses in its own anti-money laundering architecture. While MROS (Money Laundering Reporting Office) advances international cooperation, it struggles with resource shortages and a flood of suspicious activity reports that led to overload in 2025. The 1000-year-old practice of informal money transfer has evolved into a highly professional instrument for money laundering and sanctions evasion – with Switzerland as a critical node whose opaque asset recovery faces increasing international criticism.


Critical Key Questions

  • How credible is Switzerland's anti-money laundering leadership role when its own MROS is groaning under overload and international observers speak of "dithering"?
  • Where does legitimate financial market regulation end and where does de facto acceptance of shadow financial flows through institutional inertia begin?
  • What innovation opportunities emerge for FinTech players developing transparent real-time compliance solutions – and who is blocking their implementation?

Scenario Analysis: Future Perspectives

Short-term (1 year):
Tightening of EU sanctions evasion controls leads to pressure on Swiss payment service providers; MROS reform to handle the flood of reports is politically discussed but not implemented.

Medium-term (5 years):
AI-powered analysis systems enable real-time detection of underground banking patterns; without transparency reforms, Switzerland loses further reputation to Singapore and UK as a financial center.

Long-term (10-20 years):
Fully digitized currency systems (CBDCs) make classic underground banking obsolete, but shift informal systems to decentralized crypto networks; geopolitical blocs establish parallel financial systems.


Main Summary

a) Core Topic & Context

The second international Underground Banking Roundtable (Nov. 20-21, 2025) in Bern brought together experts from Interpol, Europol, UNODC and ESAAMLG to combat informal payment systems. These over 1000-year-old transfer mechanisms are primarily abused today for money laundering, terrorist financing and sanctions evasion.

b) Key Facts & Figures

  • Underground Banking has existed for over 1000 years (longer than banks themselves)
  • MROS reports overload in 2025 due to massive increase in suspicious activity reports
  • Participants: Interpol, Europol, UNODC, ESAAMLG plus national FIUs
  • Switzerland is internationally referred to as "dithering" (slow/hesitant) compared to Singapore and UK
  • [⚠️ To be verified] Specific figures on underground banking flow volumes are missing from the press release

c) Stakeholders & Affected Parties

  • Directly affected: Swiss financial center, MROS/fedpol, payment service providers
  • Internationally involved: FIUs worldwide, law enforcement agencies, regulated financial institutions
  • Indirectly affected: legitimate remittance service providers (migrants), SMEs in international trade

d) Opportunities & Risks

Opportunities:

  • Technological innovation through digital analysis methods and real-time data exchange
  • Strengthening of international cooperation structures

Risks:

  • Reputational damage to Swiss financial center due to lack of transparency
  • Systemic overload of MROS jeopardizes effective anti-money laundering efforts
  • Shift of criminal activities to even harder-to-control digital systems

e) Relevance for Action

Decision-makers should immediately address three areas:

  1. Resource allocation for MROS to handle the flood of reports
  2. Transparency offensive in asset recovery to secure reputation
  3. Technology investments in AI-based real-time analysis systems

Quality Assurance & Fact-Checking

  • Verified: MROS overload 2025 confirmed by multiple sources
  • Verified: International criticism of Swiss transparency (UNCAC Coalition)
  • [⚠️ To be verified]: Specific volumes of funds transferred via underground banking
  • [⚠️ Information gap]: Concrete investigation successes or case numbers missing from press release

Source Directory

Primary Source:
Second Underground Banking Roundtable – fedpol Press Release

Supplementary Sources:

  1. Switzerland's banks still being pulled up – finews.ch
  2. Asset recovery processes remain opaque – UNCAC Coalition
  3. Trade-Based Money Laundering Report – FATF

Verification Status: ✅ Facts checked on Nov. 21, 2025


🧭 Journalistic Compass

  • 🔍 Power structures questioned: Discrepancy between Swiss leadership claim and actual performance highlighted
  • ⚖️ Personal responsibility emphasized: Need for action on resources and transparency clearly stated
  • 🕊️ Transparency prioritized: Information gaps and unconfirmed data explicitly marked
  • 💡 Food for thought provided: Critical questions on credibility and innovation formulated