In Swiss law, there are separate regulation frameworks for both Special Financial Intermediaries and Other Financial Intermediaries. Special Intermediaries can include banks, gaming houses, stockbrokers and insurance companies. Other Intermediaries, on the other hand, can include asset management, FX, money remittance and payment and credit providers.
In Switzerland, Special Financial Intermediaries require a license and authorisation from FINMA to operate, whereas Other Financial Intermediaries can operate with supervisions from FINMA or as an SRO.
The principal rationale behind these two major differences in regulation comes down to the Swiss Federal Act on Combatting Money Laundering and Terrorist Financing, or the AMLA. This Act was introduced on October 10th 1997 and has been in action ever since. To meet the requirements set out by the AMLA Act Special Intermediaries must obtain a license from FINMA and also be authorised in accordance with all operations. An Other Financial Intermediary simply needs to choose between being an SRO (self-regulatory organisation) or be directly supervised by FINMA to ensure it complies with all laws