The Anti-Money Laundering Act states the duties of financial intermediaries briefly. The details sit in ordinances, SRO regulations and codes such as CDB 20. Knowing the structure of Articles 3 to 8 makes all those texts easier to navigate.
Identify and establish
Art. 3 AMLA requires identifying the contracting party with a document of evidentiary value when the relationship begins. Art. 4 AMLA requires establishing the beneficial owner; for operating companies that is the controlling person. Art. 5 AMLA requires re-identification when doubts arise. Together these three duties are what daily practice calls KYC.
Clarify
Art. 6 AMLA requires identifying the nature and purpose of the business relationship to an extent matching the risk. Higher risks, such as politically exposed persons, unusual transactions or indications of criminal origin, require special clarifications. This is the core of enhanced due diligence.
Document and organise
Art. 7 AMLA requires documenting the clarifications so that qualified third parties can form a reliable judgement, and periodically verifying that the records are up to date. Records must be kept for at least ten years after the relationship ends. Art. 8 AMLA requires organisational measures: internal directives, training and controls. This is where audits start when they draw samples.
Report and freeze
If a financial intermediary knows or has reasonable grounds to suspect that assets derive from a felony, it reports to MROS (suspicious activity report), which links to the asset freeze. Since 1 October 2026 adapted duties apply to certain advisers.