Run it for me01
External AML officer
A qualified outsourced AML officer for financial intermediaries that do not need a full-time hire: policies, oversight, reporting and audit liaison under one mandate.
Explore the external officerAML & compliance
for Swiss financial businesses
Every Swiss financial intermediary carries the full weight of the Anti-Money Laundering Act, whether or not it holds a FINMA licence. We build the framework that satisfies it, and run the parts you would rather not staff: the external AML officer, KYC, transaction monitoring, sanctions screening, and the annual SRO audit you have to pass.
What we run
The whole AML function, or just the parts you cannot staff.
Most clients start with the outsourced officer or audit preparation. Begin where the pressure is.
Services in detail
Eight AML services — for SRO and FINMA-supervised firms.
Build the framework once, run it month to month, and walk into the SRO audit with nothing to fix.
Front door02
KYC & onboarding
Customer and beneficial-owner identification, purpose-of-relationship checks and risk classification built into an onboarding flow your auditor and your bank both accept.
Explore this serviceOngoing03
Transaction monitoring
Risk-based monitoring rules, alert handling, and the clarification-and-documentation routine that turns flagged activity into either a cleared file or an MROS report.
Explore this serviceFoundations04
AML policy framework
The written policies, directives and procedures the law requires, drafted to your business model, not a template, so they survive scrutiny rather than sit in a drawer.
Explore this serviceAnnual05
SRO audit preparation
A pre-audit review that closes gaps before your Self-Regulatory Organisation arrives, plus liaison through the audit so findings are answered, not carried forward.
Explore this serviceRisk06
Sanctions screening
Screening against SECO, EU, UN and OFAC lists at onboarding and on a periodic re-scan, with a clear escalation path when a name matches.
Explore this serviceThe foundation07
AML risk assessment
The institution-wide risk assessment that drives the whole framework, built around your real client base, products and geographies, and the first thing the auditor reads.
Explore this servicePeople08
AML training
Role-appropriate AML training for staff and management: a documented obligation under the framework, and the difference between a policy on paper and one that works.
Explore this service
The obligation
What the Anti-Money Laundering Act actually requires.
The Anti-Money Laundering Act turns a handful of principles into concrete, auditable duties. Strip away the jargon and a Swiss financial intermediary must do six things, consistently and on the record. Miss one and the audit finds it; miss it badly and the exposure is criminal, not administrative.
| Duty | What it means in practice |
|---|---|
| Identify the customer | Verify identity at onboarding, on the record |
| Establish beneficial ownership | Find the natural person who ultimately controls |
| Document the purpose | Record why the relationship exists and is plausible |
| Monitor on a risk basis | Watch transactions; clarify the unusual |
| Keep records | Retain files for the statutory period |
| Report suspicion | File with MROS; failing to is itself an offence |
None of this is optional, and a generic template will not pass. The duties have to be calibrated to your business in a written risk assessment and then actually run. That is the difference between a framework that protects the firm and one that simply exists.
Why most firms outsource the officer
A full-time, qualified AML officer is expensive, and for a smaller financial intermediary, under-used. Delegating the function to an external provider keeps the responsibility with the firm while giving it experienced compliance cover, current on what each Self-Regulatory Organisation expects. It is the most common arrangement we run, often alongside the firm’s FINMA or SRO work and its crypto licensing.
Authoritative sources: the AMLA and its ordinances are consolidated at fedlex.admin.ch, and FINMA’s money-laundering material is at finma.ch.
Related
Where AML connects
The permission
Financial regulation
SRO membership and FINMA licensing, the authorisation the AML framework sits underneath.
Financial regulationHigh-risk sector
Crypto & digital assets
The Travel Rule and VASP-specific AML duties that crypto intermediaries carry on top of the standard framework.
Crypto & digital assetsRun the entity
Corporate administration
Substance, directorship and entity management that keep the licensed company compliant alongside its AML function.
Corporate administration
FAQ
AML compliance in Switzerland, answered.
01Who needs an AML framework in Switzerland?
Any business that acts as a financial intermediary on a professional basis (accepting, holding or transferring third-party assets) falls under the Anti-Money Laundering Act. That covers asset managers, payment and crypto businesses, fiduciaries, lenders and dealers in certain high-value goods. The duty attaches to the activity, not the licence: even an SRO member with no FINMA licence carries the full AML obligations. We confirm whether you are caught and build the framework accordingly.
02Can I outsource the AML officer function?
Yes. Swiss practice allows the AML officer (the compliance function for money-laundering matters) to be delegated to a qualified external provider, which is common for smaller financial intermediaries that do not need a full-time hire. The firm remains responsible, but the day-to-day function (policies, monitoring oversight, reporting, audit liaison) is run by us under a clear mandate. It is usually faster and cheaper than building the function in-house.
03What are the core AML duties?
Identify the customer and the beneficial owner, establish the purpose of the relationship, monitor transactions on a risk basis, clarify unusual activity, keep records, and report suspicion to the Money Laundering Reporting Office Switzerland (MROS). Higher-risk relationships require enhanced due diligence. Crypto businesses add the FATF Travel Rule. We turn these duties into written policies and a monitoring routine your auditor will accept.
04How does the SRO audit work?
Each Self-Regulatory Organisation audits its members at least annually for AML compliance, reviewing your risk assessment, files, monitoring and reporting. Findings can lead to remediation deadlines or, in serious cases, expulsion, which usually ends the business. We prepare the file, close gaps before the auditor arrives, and act as the point of contact through the audit cycle.
05What is a risk-based approach?
Swiss AML law does not require the same checks on everyone: it requires checks proportionate to the money-laundering risk of each relationship. You classify clients by risk (country, activity, structure, transaction pattern), apply standard or enhanced due diligence accordingly, and document why. The written risk assessment is the foundation of the whole framework, and the first thing an auditor reads. We build it around your actual client base.
06What happens if AML compliance fails?
Breaching AML duties is serious. It can trigger SRO sanctions, FINMA enforcement, criminal liability for the responsible individuals, frozen banking relationships, and reputational damage that closes the business to counterparties. Failing to report a genuine suspicion is itself an offence. The point of a working framework is not paperwork: it is keeping the business and its principals out of that exposure.
07Do you screen against sanctions?
Yes. Sanctions screening (against the SECO list, and EU, UN and OFAC lists where relevant) is part of onboarding and ongoing monitoring, and it is distinct from AML but runs alongside it. A single sanctioned counterparty can expose the firm to criminal and reputational risk. We set up screening at onboarding and as a periodic re-scan, with an escalation path for matches.
08How long must AML records be kept?
Ten years. The Anti-Money Laundering Act requires a financial intermediary to keep the records that let each transaction and verification be reconstructed (identification documents, the establishment of the beneficial owner, the risk profile and transaction records) for ten years after the relationship ends or the transaction is completed. The records must be available in Switzerland and retrievable within a reasonable time. We build the retention and filing system into the AML framework, not as an afterthought.
09How do we identify the beneficial owner?
By looking through the contracting party to the natural person who ultimately controls it. In practice the intermediary obtains a written declaration: Form A for the beneficial owner of the assets, and a controlling-person declaration for operating companies, where control is presumed at a 25 percent shareholding or, failing that, the most senior managing person. The duty applies even where the client is a company or a trust. We provide the forms, the decision logic and the file documentation an SRO audit will check.
10When must we report a suspicion, and to whom?
To the Money Laundering Reporting Office Switzerland (MROS), the federal financial-intelligence unit, under Article 9 of the Anti-Money Laundering Act. A report is mandatory where the intermediary knows or has reasonable grounds to suspect that assets are connected to money laundering, a predicate offence, a criminal organisation or terrorist financing. Filing is a legal duty, not a discretion, and tipping off the client is prohibited. We set the escalation path and support the AML officer through the reporting decision.
Need an AML framework or an external officer?
Tell us what the business does and who supervises it. A partner replies with the AML duties that apply and how we would run them: in-house support or a fully outsourced officer.