AML Advisory for Portfolio Managers

The Swiss Anti-Money Laundering Act (AMLA) requires portfolio managers, trustees, managers of collective assets and other financial intermediaries to have an organisation that effectively counters money laundering and terrorist financing and, since 1 October 2026, also takes into account coercive measures under the Embargo Act. With AML advisory from Peak Compliance, you have experienced specialists at your side: your risk analysis and directives fit your business model, responsibilities are clearly assigned, and your board of directors, executive management, supervisor and audit firm can follow every step. You meet your duties reliably and can focus on your clients.

What does AML advisory cover?

Peak Compliance advises on the organisational duties under the Anti-Money Laundering Act and works with you to develop the necessary framework. For portfolio managers, trustees and managers of collective assets, the FINMA Anti-Money Laundering Ordinance applies (Art. 3 AMLO-FINMA):

Money laundering risk analysis: the anti-money laundering unit or another independent body prepares the risk analysis; it takes into account in particular the client's registered office or domicile, the client segment and the products and services offered, is approved by the board of directors or the highest management body and is updated periodically (Art. 25 para. 2 AMLO-FINMA). Peak Compliance prepares or revises the analysis, taking into account FINMA's observations on risk tolerance, key risk indicators and net risks set out in FINMA Guidance 04/2026.
Internal directives: the board of directors or the highest management body approves the directives on combating money laundering and terrorist financing. Among other things, they set out the criteria for higher risks, the principles of transaction monitoring, the business policy on politically exposed persons and responsibility for reports (Art. 26 AMLO-FINMA). Peak Compliance drafts the directives, aligns them with your processes and keeps them up to date.
Anti-money laundering unit: the financial intermediary designates one or more qualified persons as its anti-money laundering unit. The unit advises line managers and executive management, prepares the directives and plans and monitors internal training (Art. 24 AMLO-FINMA); under its own responsibility, the institution may also designate qualified external persons, for example where an in-house unit would be disproportionate (Art. 25 para. 4 AMLO-FINMA). Peak Compliance clearly allocates the unit's tasks and interfaces and, on request, takes on the role itself.
Periodic review: the required records are checked periodically to ensure that they are up to date and are updated where necessary; the frequency, scope and type of review depend on the risk posed by the client (Art. 7 para. 1bis AMLA). Peak Compliance sets the risk-based review cycle and supports you with reviews and remediation projects, particularly for domiciliary companies and complex structures.
Transparency Register: since 1 October 2026, companies report the identity of their beneficial owners to the Transparency Register (Art. 9 TLPA). Peak Compliance determines the reporting deadline with you, identifies the beneficial owners and prepares the filing via EasyGov.
Sanctions and embargoes: since 1 October 2026, the organisational measures under Art. 8 AMLA expressly include preventing breaches of coercive measures under the Embargo Act. Peak Compliance embeds screening against sanctions lists in your directives and controls and, on request, performs ongoing screening; background is provided in our article on sanctions and embargoes.
Reporting: financial intermediaries report immediately to the Money Laundering Reporting Office Switzerland (MROS) if they know or have reasonable grounds to suspect that assets involved in a business relationship are, for example, the proceeds of a felony (Art. 9 AMLA). Peak Compliance supports the clarification and the report in a structured way and records responsibilities in the directives.
Audit support: Peak Compliance prepares the documents for the regulatory audit, answers the auditors' questions, attends the closing meeting with the audit firm and follows up on open measures until they are completed.

Project-based advice or an ongoing AML unit

AML advisory suits clearly defined projects: a new or revised risk analysis, aligning your directives with the revised AMLA (in force since 1 October 2026), preparing for an audit or clarifying an individual case. You receive documents ready for approval, and your team continues to run the processes in day-to-day business.

If you would like these tasks to remain with Peak Compliance permanently, Peak Compliance runs the anti-money laundering unit through compliance outsourcing, either as part of the entire compliance function or as a single task. You receive a dedicated contact person with a deputy when an outsourced compliance officer takes over the compliance function. Both models can be combined with project-based advice, for example for a project alongside the ongoing mandate.

How does AML advisory work?

1
Initial consultation
you describe your business model, client base and question; Peak Compliance clarifies your needs and the scope of the mandate.
2
Analysis
Peak Compliance reviews your risk analysis, directives, processes and controls and records which elements already provide a sound basis and where adjustments are advisable.
3
Drafting
Peak Compliance prepares the agreed documents and processes, coordinates them with you and prepares them for approval by the board of directors or executive management.
✓
Implementation and support
your team applies the new framework in day-to-day business; on request, Peak Compliance supports the next audit or acts as your anti-money laundering unit on an ongoing basis.

Legal basis

Art. 8 AMLA: financial intermediaries take the organisational measures needed to prevent money laundering, terrorist financing and breaches of coercive measures under the Embargo Act; in particular, they ensure adequate staff training and controls.
Art. 9 AMLA: report to the Money Laundering Reporting Office Switzerland where the financial intermediary knows or has reasonable grounds to suspect.
Art. 24 AMLO-FINMA: designation of the anti-money laundering unit; advice, preparation of the directives, planning and monitoring of training.
Art. 25 AMLO-FINMA: monitoring of compliance with the duties, risk analysis (para. 2) and external anti-money laundering unit (para. 4).
Art. 26 AMLO-FINMA: internal directives, approved by the board of directors or the highest management body.
Art. 27 AMLO-FINMA: careful selection and regular training of staff.
FINMA Guidance 04/2026: supplement to Guidance 05/2023 on the money laundering risk analysis; FinIA institutions may apply the observations by analogy.

English versions of Swiss federal law are provided for information only; the German, French and Italian texts are authoritative. The AMLO-FINMA is published in German, French and Italian; links to it point to the French text.

AML training, SRO affiliation and compliance outsourcing: how the services fit together

AML training: regular staff training under Art. 27 AMLO-FINMA is covered by our AML training, on site or via e-learning; the risk analysis and directives from the advisory work feed directly into the training content.
SRO affiliation: for financial intermediaries joining a self-regulatory organisation (SRO), Peak Compliance supports the affiliation application (SRO affiliation); afterwards, AML advisory supports you with directives, clarifications and reporting.
Compliance outsourcing: Peak Compliance runs the ongoing anti-money laundering unit as part of the second line of defence through compliance outsourcing; AML advisory covers individual projects and questions.

Why Peak Compliance

Practical experience: Peak Compliance runs anti-money laundering units, including onboarding reviews, remediation projects and reviews supported by specialised IT tools.
Supervisory experience: mandates with portfolio managers supervised by FINMA and the FMA and cooperation with the supervisory organisations AOOS and OSFINcontrol.
Traceable documentation: Peak Compliance records controls and open items in a fully digital internal control system.
Expertise: articles, for example on due diligence duties under the Anti-Money Laundering Act; provisions and further articles are brought together in the knowledge hub on the Anti-Money Laundering Act and sanctions.

Plan your AML advisory with Peak Compliance: book an initial consultation via the contact page.

At a glance


Who it is for	Portfolio managers and trustees (Art. 17 FinIA), managers of collective assets (Art. 24 FinIA) and other financial intermediaries under the Anti-Money Laundering Act
What	Advice on the duties under the AMLA and AMLO-FINMA: risk analysis, directives, anti-money laundering unit, periodic review, Transparency Register, sanctions, reporting and audits
Legal basis	Art. 8 AMLA; Arts. 24–27 AMLO-FINMA; FINMA Guidance 04/2026
How	On a project basis as a defined mandate or on an ongoing basis as your anti-money laundering unit; on site and remotely
When	After an initial consultation and an analysis of your business model and existing documents
Pricing	Proposal based on the analysis and the agreed scope

Frequently asked questions

What does AML advisory from Peak Compliance cover?

It covers the money laundering risk analysis, the internal directives, the organisation of the anti-money laundering unit, the periodic review of client records, the Transparency Register, sanctions and embargoes, reporting to the Money Laundering Reporting Office Switzerland and support during the regulatory audit. The legal basis is Art. 8 AMLA and, for portfolio managers and managers of collective assets, Arts. 24–27 AMLO-FINMA. You define the scope together with Peak Compliance after the initial consultation: as a single project or as an ongoing anti-money laundering unit through compliance outsourcing.

What is the anti-money laundering unit?

The anti-money laundering unit consists of one or more qualified persons designated by the financial intermediary. It supports and advises line managers and executive management in implementing the AMLO-FINMA, while responsibility remains with them; it also prepares the internal directives and plans and monitors training (Art. 24 AMLO-FINMA). If the institution is unable, owing to its size or organisation, to set up its own unit, or if doing so would be disproportionate, it may designate qualified external persons under its own responsibility (Art. 25 para. 4 AMLO-FINMA). Peak Compliance takes on this role on request.

Who prepares the money laundering risk analysis?

The anti-money laundering unit or another independent body; the board of directors or the highest management body approves the analysis, and it is updated periodically (Art. 25 para. 2 AMLO-FINMA). According to FINMA Guidance 04/2026, the only exception applies to small institutions under Art. 75 para. 1 AMLO-FINMA, for example portfolio managers and trustees with five or fewer full-time positions or annual gross income of less than CHF 2 million and a business model without higher risks; FINMA may also require these institutions to perform the tasks under Art. 25 AMLO-FINMA (Art. 75 para. 2). Peak Compliance develops the analysis with you and prepares it for approval.

What does FINMA Guidance 04/2026 contain?

Guidance 04/2026 of 4 June 2026 supplements Guidance 05/2023 on the money laundering risk analysis under Art. 25 para. 2 AMLO-FINMA. FINMA describes the risk analysis as the key management tool and sets out observations on risk tolerance with deliberate exclusions, the exception to policy process, key risk indicators, net risks and risk limits. Portfolio managers, trustees and managers of collective assets may apply the observations by analogy, in line with the nature, scope, complexity and risk profile of their business activities. Peak Compliance aligns your risk analysis with these points.

Sources

Responsible

Isabelle Ledergerber

Managing Partner, Co-Founder · LinkedIn profile

AML advisory for portfolio managers and financial intermediaries