SwissAML
Each section presents the regulatory requirement, the obligation it creates for trust companies, law firms, and fiduciaries, and how SwissAML addresses it. Source legislation is linked for verification.
Source legislation
Federal Act on Combating Money Laundering and Terrorist Financing (SR 955.0), status as of 1 March 2024
Regulation
When establishing a business relationship, the financial intermediary must verify the identity of the customer on the basis of a document of evidentiary value. Where the customer is a legal entity, the intermediary must verify the identity of the persons entering the business relationship on behalf of the legal entity.
Obligation
Positive identification of each customer at relationship inception using evidentiary documents. Legal entity representatives must be separately identified.
SwissAML response
We provide Know Your Customer (KYC) client profiles with structured data capture: full name, date of birth, nationality, occupation, identity document type/number/expiry. Separate onboarding flows for natural persons and legal entities. Document upload with status lifecycle tracking.
Regulation
The financial intermediary must identify the beneficial owner with due diligence and verify its identity. A written declaration must be obtained when the customer is not the beneficial owner, is a domiciliary company, or is an operating legal entity. Beneficial owners are natural persons who hold at least 25 per cent of the capital or voting rights, or otherwise control the entity.
Obligation
Beyond identifying the customer, intermediaries must establish who ultimately owns or controls the assets. The 25% threshold is statutory. Written declarations required for legal entities.
SwissAML response
We provide an Ultimate Beneficial Owner (UBO) module with ownership percentage, control basis, and verification status. Interactive ownership structure visualisation. Trust-specific roles: settlor, trustee, protector, beneficiary. Live screening against Office of Foreign Assets Control (OFAC), European Union (EU), United Nations (UN), and State Secretariat for Economic Affairs (SECO) sanctions lists. The platform enables your firm to apply the 25% ownership threshold systematically.
Regulation
The financial intermediary must ascertain the nature and purpose of the business relationship. The extent of information, decision-making level, and regularity of checks are determined by the risk represented by the customer. Enhanced clarification is required when transactions appear unusual, carry higher risk, or involve Politically Exposed Persons (PEPs).
Obligation
Risk-proportionate due diligence. Enhanced scrutiny for unusual transactions, higher-risk relationships, and all Politically Exposed Person (PEP) relationships. Decision-making authority must match the risk level.
SwissAML response
We provide a seven-factor automated risk engine: jurisdiction, structure complexity, Politically Exposed Person (PEP) status, sanctions screening, product type, work type, client profile. Four risk bands (low, medium, high, critical). Automated compliance gates: Enhanced Due Diligence (EDD) triggers, senior approval requirements. Politically Exposed Person (PEP) screening with automatic risk elevation.
Regulation
The financial intermediary must keep records of transactions and clarifications so that other specially qualified persons can make a reliable assessment. Records must be periodically checked and updated based on risk. After termination, records must be retained for a minimum of ten years.
Obligation
Comprehensive record-keeping to a standard enabling independent assessment. Periodic review based on risk. Ten-year minimum retention.
SwissAML response
We provide a comprehensive audit trail: each action logged with timestamp, user identity, and IP address. Three-tier visibility for examination. Immutable records. Date and event type filtering. Mandate reports for regulatory submission.
Regulation
A financial intermediary must immediately file a report with the Money Laundering Reporting Office Switzerland (MROS) if it knows or has reasonable grounds to suspect that assets are connected to an offence, are proceeds of a felony, or are subject to a criminal organisation. Reasonable grounds exist when the intermediary has specific evidence or several indications that cannot be dispelled by further clarification.
Obligation
Mandatory reporting to the Money Laundering Reporting Office Switzerland (MROS) when suspicion cannot be resolved through Enhanced Due Diligence (EDD). Reports must be filed immediately.
SwissAML response
We provide an alert system with status lifecycle. Money Laundering Reporting Office Switzerland (MROS) reference and filing date tracking. Compliance recommendations auto-generated from the risk engine. Escalation workflow from screening hit to resolution. goAML XML report generation for direct Money Laundering Reporting Office Switzerland (MROS) filing with five-step filing interface.
Financial Action Task Force (FATF) Recommendations (2012, updated February 2025)
Regulation
Financial institutions must undertake Customer Due Diligence (CDD) when establishing business relations, carrying out occasional transactions, when there is a suspicion of money laundering, or when there are doubts about identification data. Customer Due Diligence (CDD) measures: identify the customer, identify the beneficial owner, understand the purpose, conduct ongoing due diligence.
Obligation
Four-pillar Customer Due Diligence (CDD): identify customer, identify beneficial owner, understand purpose, ongoing monitoring. Risk-based approach to determine the extent of measures.
SwissAML response
We cover all four Customer Due Diligence (CDD) pillars: Know Your Customer (KYC) client profiles, Ultimate Beneficial Owner (UBO) module with ownership chain mapping, mandate documentation with purpose and source of funds, risk-based monitoring with automated review triggers.
Regulation
Countries should ensure adequate, accurate, and up-to-date information on the beneficial ownership and control of legal persons, accessible to competent authorities through a register or alternative mechanism.
Obligation
Beneficial ownership information for legal persons must be adequate, accurate, up-to-date, and accessible to authorities.
SwissAML response
We provide beneficial ownership records with ownership percentage, control basis, and verification status. Support for complex legal entity structures. Audit-trailed records with timestamp verification.
Regulation
Countries should ensure adequate, accurate, and up-to-date information on express trusts, including information on the settlor(s), trustee(s), and beneficiary(ies), accessible to competent authorities.
Obligation
Trust structures must be transparent. Settlor, trustee, and beneficiary information must be recorded and available.
SwissAML response
We provide trust-specific party roles: settlor, trustee, protector, beneficiary, enforcer. Each role linked to natural or legal person with full identity records and screening.
Swiss Financial Market Supervisory Authority (FINMA) Circular 2011/1, last amended 4 November 2020
Regulation
Specifies how the Swiss Financial Market Supervisory Authority (FINMA) interprets the Anti-Money Laundering Act (AMLA) and the Anti-Money Laundering Ordinance (GwV) regarding professional activity thresholds and operational requirements for each category of financial intermediation.
Obligation
Trust companies, law firms, and fiduciaries must understand which activities subject them to the Anti-Money Laundering Act (AMLA) and the specific due diligence requirements for their category.
SwissAML response
SwissAML provides compliance tooling for intermediaries already subject to the Anti-Money Laundering Act (AMLA). The audit trail and record-keeping are designed for Self-Regulatory Organisation (SRO) inspection as specified in this circular.