SRO affiliation & AML setup

No. The product, trading model and role of the business matter. Banking precious metals, jewellery, scrap purchases, melting and assaying can raise different requirements. Certain trade assayers and related businesses fall under the Central Office for Precious Metals Control. We assess the activity before selecting SRO affiliation or another supervisory route.

Professional financial intermediaries subject to AMLA that do not fall within another applicable supervisory route may need membership of a recognized SRO. Payment, exchange and some crypto activities are common examples. We first assess the actual service and any separate licensing requirements.

The analysis can involve revenue, the number and duration of business relationships, control over third-party assets and transaction volume. The applicable tests and exceptions must be checked together. A low transaction value or an early-stage business description does not by itself settle the question.

The former directly subordinated financial intermediary status was abolished from 2020. An eligible AML-only business should therefore assess the current SRO route rather than rely on historic registration language. Firms with an institutional license follow the AML supervision attached to that status.

No. It establishes an AML supervisory relationship for the relevant activity. It does not authorize banking, professional portfolio management or other separately licensed business. We assess that boundary before preparing the admission file.

FINMA’s published 2026 list contains 11 recognized SROs. Admission scope, sector focus, rules, language and costs differ. We use the current register and the proposed business model to identify suitable organizations rather than send a generic application to all of them.

Suitability depends on the activity and whether the organization can assess the proposed custody, onboarding and transfer arrangements. Experience with crypto is useful, but does not remove admission requirements. The application should explain the technology in terms of actual AML risks and controls.

The operating entity and its Swiss connection need to fit the applicable AML framework and the SRO’s admission rules. Incorporation, management, premises and responsible persons should be planned together. We can sequence preparatory work while those arrangements are being established.

Timing depends on the chosen SRO, the business model, document completeness and follow-up questions. Establishing the entity and recruiting suitable people can be critical dependencies. We set a preparation schedule and distinguish it from the organization’s admission review.

Budget for admission and membership charges, AML audits, staff, training and any monitoring tools. These are separate from our legal fee. The proposal identifies the documents and response work included so initial setup and continuing costs can be compared clearly.

A template can provide a starting structure, but the procedures must reflect the business’s customers, products, countries and transactions. We review who performs each control, what evidence is retained and how exceptions are escalated. Policies should match the operation described in the application.

The firm must assign operational duties and decision authority to competent people or properly appointed providers. A legal setup project does not automatically include reviewing each customer or transfer. Any continuing support or officer role is expressly scoped, including access and reporting.

The firm must apply its AML procedures, maintain records, train relevant staff and meet the SRO’s audit and reporting requirements. Changes to activities, responsible persons or risk exposure should be checked against the membership conditions and notification rules.

Proposals for new crypto and payments categories may affect which supervisory route applies. We distinguish announced reforms from effective law and monitor any adopted transition requirements. Existing affiliation should not be assumed to cover a future activity without another review.