The Swiss system of anti-money laundering supervision has a particular feature: a large share of financial intermediaries is supervised not directly by the state but by private organisations, which are in turn recognised and overseen by FINMA. These self-regulatory organisations are the backbone of supervision over fiduciaries, payment service providers and other intermediaries outside prudential supervision.
Who must join
Financial intermediaries not already under FINMA’s prudential supervision must join an SRO. Since 1 October 2026 this also applies to advisers carrying out certain activities, for example in connection with real estate transactions or the formation and establishment of non-operating legal entities. The transitional period for the membership application ends in December 2026; the chosen SRO confirms the exact cut-off date and requirements. See our checklist on AMLA coverage for advisers.
What an SRO does
It issues regulations that specify the due diligence duties of the Anti-Money Laundering Act for its members: identification, establishing the beneficial owner, risk classification, additional enquiries, documentation, training. It has compliance checked by audit firms, offers training and sanctions breaches, from fines to expulsion. Expulsion matters, because without membership the activity may no longer be carried out.
SRO, supervisory organisation and FINMA
Since the Financial Institutions Act (FinIA), independent asset managers and trustees need a FINMA licence and are supervised on an ongoing basis by a supervisory organisation (SO). That is a different model from the SRO. Banks, insurers and other prudentially supervised institutions report directly to FINMA. Those working with several service providers around a family often deal with three supervisory routes at once.
Which SRO
There are several recognised SROs, some sector-specific, for example for lawyers and notaries or for fiduciaries, others cross-sector. FINMA keeps the authoritative list. The choice depends on sector fit, regulations, audit model, training offering and cost. Anyone newly subject should read the regulations before applying: they determine what daily life with the due diligence duties looks like.
The audit
SRO audits look at samples of files. The question is whether duties were fulfilled and decisions are traceable: where is the risk classification, where the reasoning, where the evidence? Organisations with a clean audit trail pass with considerably less effort than those that gather files before the audit.