Switzerland's financial sector operates under one of the world's most rigorous regulatory frameworks, designed to prevent money laundering, protect investors, and maintain the country's reputation as a stable financial hub. For international entrepreneurs, fintech startups, and wealth managers seeking to establish operations in Switzerland, understanding the regulatory landscape for financial intermediaries is essential. This article explains who qualifies as a financial intermediary, the two main paths to authorization—direct FINMA licensing or membership in a self-regulatory organization (SRO)—and the practical steps required to achieve compliance in 2025. > "Over the past decade, I have guided more than 40 international clients through the Swiss financial intermediary authorization process. The most common misconception is that all financial services require a full FINMA banking license. In reality, many businesses—asset managers, payment providers, crypto exchanges—can operate under SRO supervision, which is faster, less capital-intensive, and perfectly suited for mid-sized firms and startups." — Markus Pritzker, Swiss Corporate Lawyer ## Types of financial intermediary activities requiring regulation Not all financial operations in Switzerland trigger the same level of regulatory oversight. The Swiss Anti-Money Laundering Act (AMLA) defines specific activities that require supervision, either directly by FINMA or through an SRO. > "Financial intermediaries must become members of a self‑regulatory organisation (SRO) as a way of preventing money laundering." — FINMA, Self-regulatory organisations (SROs), 2025 ## Overview of financial intermediary regulation in Switzerland Switzerland regulates financial intermediaries primarily to combat money laundering and terrorist financing. The legal foundation is the Federal Act on Combating Money Laundering and Terrorist Financing (AMLA), which came into force in 1998 and has been revised multiple times. AMLA defines a financial intermediary as any person who, on a professional basis, accepts or holds assets belonging to third parties or assists in the investment or transfer of such assets. The regulatory system operates on a dual-track model. Entities engaged in prudentially supervised activities—such as banks, securities firms, and large asset managers—must obtain direct authorization from the Swiss Financial Market Supervisory Authority (FINMA). Non-prudentially supervised intermediaries, including independent asset managers, payment service providers, and crypto platforms, are required to affiliate with a FINMA-recognized self-regulatory organization (SRO) for anti-money laundering (AML) supervision. This dual structure allows Switzerland to maintain strict AML standards while offering a proportionate regulatory path for smaller and specialized financial service providers. SROs conduct periodic audits, enforce due diligence procedures, and report to FINMA, which retains ultimate oversight authority. As of 2025, FINMA recognizes 11 SROs, including VQF (the largest and oldest), ARIF, and PolyReg. {{cta:cta-1}} ## FINMA licensing vs. SRO membership: which path to choose? Choosing between direct FINMA licensing and SRO membership depends on the nature of your business, capital availability, and strategic goals. FINMA licensing is mandatory for banks, insurance companies, securities dealers, and certain asset managers. SRO membership is the appropriate route for independent asset managers, payment providers, fintech startups, and crypto service providers that do not fall under FINMA's prudential supervision.

Option A

Direct FINMA Licensing

Best Suited For

Banks, securities dealers, insurance companies.

Supervision Level

Intensive prudential oversight, capital adequacy, risk rules.

Cost & Timeline

High (often > CHF 100k). Lengthy process (6–12 months or more).

Typical Scope

Accepting public deposits; prudentially regulated activities.

Option B
(Recommended for Startups)

SRO Membership

Best Suited For

Independent asset managers, fintech, crypto exchanges, payment providers, fiduciaries.

Supervision Level

Delegated supervision focused on AML/CTF compliance and conduct rules.

Cost & Timeline

Moderate (CHF 15–25k initial). Faster process (2–4 months).

Typical Scope

Non-bank intermediaries under AMLA; no public deposits.

Caption: Comparison of FINMA licensing and SRO membership for financial intermediaries in Switzerland. Official resources: - [FINMA list of recognized SROs](https://www.finma.ch/en/~/media/finma/dokumente/bewilligungstraeger/pdf/sro.pdf?la=en) - [VQF (Financial Services Standards Association)](https://www.sro-vqf.ch/en/ ) - [ARIF (Association Romande des Intermédiaires Financiers)](https://www.arif.ch/en/) ## The Swiss Anti-Money Laundering Act (AMLA) and its requirements The Swiss Anti-Money Laundering Act (AMLA) is the cornerstone of financial intermediary regulation in Switzerland. Its primary objectives are to prevent the misuse of the financial system for money laundering and terrorist financing, and to align Swiss standards with international frameworks established by the Financial Action Task Force (FATF). The Swiss Parliament adopted a revision on 26 September 2025, which expands the scope of AMLA to include certain advisory professions (lawyers, notaries) when they engage in high-risk transactions, and lowers the cash transaction threshold for precious metals dealers to CHF 15,000. The revision is expected to enter into force in mid-2026. AMLA imposes a comprehensive set of obligations on financial intermediaries. These include customer due diligence (identifying clients and beneficial owners), transaction monitoring, record retention for ten years, and immediate reporting of suspicious activities to the Money Laundering Reporting Office Switzerland (MROS). Intermediaries must also appoint an internal AML compliance officer, conduct regular staff training, implement automated transaction monitoring systems, and undergo independent audits by FINMA-approved auditors. ### Key obligations under AMLA Financial intermediaries must identify and verify the identity of every client at the start of a business relationship or when conducting a transaction exceeding CHF 20,000. This process includes collecting official identification documents (passport, company registration), verifying the client's address, and understanding the nature and purpose of the business relationship. For legal entities, intermediaries must establish the identity of beneficial owners—individuals who ultimately own or control at least 25% of the entity or exercise control through other means. Intermediaries are required to file suspicious activity reports (SARs) with MROS whenever they have reasonable grounds to suspect that assets are connected to money laundering, terrorist financing, or criminal activity. Failure to report can result in severe penalties, including fines and withdrawal of authorization. Additionally, intermediaries must retain all transaction records, client identification documents, and correspondence for a minimum of ten years to facilitate regulatory audits and investigations. ### Due diligence procedures (KYC) Due diligence procedures, commonly referred to as "Know Your Customer" (KYC), are the operational core of AMLA compliance. Standard due diligence applies to most clients and involves verifying identity, assessing the client's risk profile, and understanding the source of funds. Enhanced due diligence (EDD) is required for high-risk clients, including politically exposed persons (PEPs), clients from jurisdictions on the FATF blacklist, and complex offshore structures. EDD measures include obtaining additional documentation (proof of wealth, business references), conducting background checks, and applying more frequent transaction monitoring. For PEPs—individuals holding prominent public positions or their close associates—intermediaries must obtain senior management approval before establishing the relationship and conduct ongoing scrutiny of all transactions.

AML Due Diligence Flow

Standard onboarding procedure for Swiss Intermediaries

Client Identification

Collect passport, company registration, and proof of address.

Beneficial Owner Verification

Identify individuals with ≥25% ownership or control; verify via registers and documentation.

Risk Assessment

Evaluate geography, business type, ownership complexity, and PEP status. Assign Low/Medium/High score.

Apply Measures

Implement standard CDD or Enhanced Due Diligence (EDD) based on risk.

Ongoing Monitoring

Continuously monitor transactions; periodically update profiles; report suspicious activity to MROS.

### Combating terrorist financing AMLA includes specific provisions to prevent the financing of terrorism. Financial intermediaries must screen all clients and transactions against official sanctions lists maintained by the Swiss State Secretariat for Economic Affairs (SECO) and the United Nations. Screening must be conducted at onboarding and repeated periodically based on the client's risk profile. The European Union and U.S. Office of Foreign Assets Control (OFAC) lists are recommended as best practice for comprehensive risk management. If a match is found, the intermediary must immediately freeze the assets and report the case to MROS and the relevant authorities. Failure to comply with sanctions screening obligations can result in criminal liability, substantial fines, and reputational damage. Many intermediaries use automated screening software to ensure real-time compliance with evolving sanctions lists. Official source: [Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)](https://www.fedlex.admin.ch/eli/cc/1998/892_892_892/en) ## How to obtain a financial intermediary license or SRO membership Obtaining authorization as a financial intermediary in Switzerland requires careful preparation, thorough documentation, and adherence to regulatory timelines. The process differs depending on whether you pursue direct FINMA licensing or SRO membership, but both paths demand a clear business plan, robust internal controls, and demonstrated compliance with AMLA. 1. Define your business activity and choose the regulator. Determine whether your activities fall under FINMA's prudential supervision (banks, securities firms, large asset managers) or qualify for SRO membership (independent asset managers, payment providers, crypto platforms). Review FINMA's official guidance and consult with a Swiss legal adviser to confirm your classification. 2. Prepare the business plan and internal documentation. Develop a detailed business plan that describes your services, target clients, revenue model, and risk management framework. Draft internal AML policies covering customer due diligence, transaction monitoring, record retention, and suspicious activity reporting. Prepare an organizational chart showing key personnel, including the AML compliance officer, and document their qualifications and experience. 3. Submit the application and supporting documents. For FINMA licensing, submit a formal application through FINMA's online portal, including the business plan, AML policies, proof of minimum capital, shareholder and beneficial owner declarations, and CVs of directors and senior management. For SRO membership, submit the application to your chosen SRO (e.g., VQF, ARIF, PolyReg) along with similar documentation, proof of Swiss company registration, and confirmation of financial sufficiency. 4. Undergo the regulator's review process. FINMA or the SRO will review your application, request clarifications, and may conduct on-site visits or interviews with key personnel. FINMA's review typically takes 3–6 months and involves detailed scrutiny of capital adequacy, governance structures, and IT systems. SRO reviews are generally faster (2–4 months) and focus on AML compliance and operational readiness. 5. Receive authorization and commence operations. Upon successful completion of the review, FINMA will issue a formal license, or the SRO will grant membership and register you on the public SRO member list. You may then begin operations, subject to ongoing supervision, periodic audits, and annual reporting obligations. ## Get expert assistance for your business in Switzerland Navigating Switzerland's financial intermediary regulations can be complex, particularly for international businesses unfamiliar with FINMA's requirements and the SRO landscape. SwissFirma specializes in guiding entrepreneurs, fintech startups, and established firms through the entire authorization process—from selecting the appropriate regulatory path to preparing documentation, liaising with regulators, and ensuring ongoing compliance. {{cta:cta-1}} ## Conclusion: the enduring role of Swiss regulation Switzerland's regulatory framework for financial intermediaries reflects the country's commitment to financial integrity, investor protection, and alignment with international anti-money laundering standards. The dual-track system—direct FINMA licensing for prudentially supervised entities and SRO membership for non-bank intermediaries—offers flexibility while maintaining rigorous oversight. For international entrepreneurs, fintech innovators, and wealth managers, understanding the distinction between these paths and the specific requirements of AMLA is essential for successful market entry and long-term compliance. Looking ahead, Switzerland continues to adapt its regulatory approach to emerging trends. The Federal Council's adoption of the Crypto-Asset Reporting Framework (CARF) in 2025, which mandates automatic exchange of tax information on crypto assets with 74 jurisdictions starting in 2026, signals the country's proactive stance on digital finance. Similarly, proposed amendments to the Financial Institutions Act (FinIA), currently under consultation until February 2026, aim to introduce new FINMA licenses for payment and crypto institutions, gradually phasing out SRO supervision for certain activities. These developments underscore the importance of staying informed and working with experienced advisers to navigate Switzerland's evolving regulatory landscape. Disclaimer: This information is for general guidance only and does not constitute legal or financial advice. Regulatory requirements may vary depending on your specific business model and circumstances. We recommend consulting with a qualified Swiss legal adviser before making any decisions regarding financial intermediary authorization.

Financial intermediary in Switzerland: regulation and licensing