Do portfolio managers apply the AMLO-FINMA?

Yes. Portfolio managers and trustees licensed under FinIA are financial intermediaries under Art. 2 para. 2 let. abis AMLA. The AMLO-FINMA applies to them, with special provisions for this group in its Title 5. The supervisory organisation checks compliance with AMLA duties as part of ongoing supervision (Art. 84 FinIO).

How often must client files be reviewed?

The AMLA requires financial intermediaries to check periodically whether client records are up to date and to update them where necessary; frequency, scope and type of the review depend on the client's risk (Art. 7 para. 1bis AMLA). In practice, higher-risk relationships are reviewed more often than standard ones.

Who decides on relationships with foreign politically exposed persons?

Under the AMLO-FINMA, the executive management or at least one of its members decides on taking up such relationships and, every year, on continuing them (Art. 19 AMLO-FINMA). Peak Compliance prepares the decision basis as anti-money laundering unit.

Swiss AMLA Due Diligence for Portfolio Managers: A Practical Guide

What it is about

Every licensed portfolio manager in Switzerland is a financial intermediary under the AMLA (Art. 2 para. 2 let. abis AMLA). Anti-money laundering due diligence therefore runs through the whole client lifecycle – from onboarding to periodic review and, where needed, a report to the Money Laundering Reporting Office (MROS). This guide sets out what the law requires and how to organise it in daily practice. The legal overview is in our AML knowledge hub.

What applies: the core duties

Duty	Provision	In practice
Verify the identity of the client	Art. 3 AMLA	document of evidentiary value; for legal entities, signing powers and the persons acting
Establish the beneficial owner	Art. 4 AMLA	written declaration where the client is a domiciliary company or an operating legal entity, or in case of doubt
Repeat identification	Art. 5 AMLA	when doubts arise during the relationship
Clarify nature and purpose; special due diligence	Art. 6 AMLA	client profile; additional clarifications for unusual or higher-risk relationships
Keep records up to date	Art. 7 AMLA	records that a qualified third party can assess; periodic risk-based review (para. 1bis); retention for at least ten years
Organisational measures	Art. 8 AMLA	directives, staff training and checks, including measures against violations of sanctions under the Embargo Act
Report	Art. 9 AMLA	report to MROS immediately in case of knowledge or reasonable grounds for suspicion

Business relationships with foreign politically exposed persons and their family members or close associates always count as higher risk (Art. 6 para. 3 AMLA). For domestic PEPs and PEPs in international organisations, a higher risk arises in combination with further risk criteria (Art. 6 para. 4 AMLA).

What the AMLO-FINMA adds

The FINMA ordinance turns these duties into an organisational framework (current version; a partial revision is planned for 1 January 2027):

Criteria for higher risks: the firm develops criteria such as domicile and nationality, type of services, amount of assets, inflows and outflows and the complexity of structures, and records for each criterion whether it is relevant (Art. 13 AMLO-FINMA). Portfolio managers with up to 20 permanent business relationships may dispense with these criteria (Art. 72 para. 1 AMLO-FINMA).
Approval: taking up higher-risk relationships requires approval by a superior, a higher body or the executive management (Art. 18 AMLO-FINMA).
Monitoring: effective monitoring of business relationships and transactions to identify higher risks (Art. 20 AMLO-FINMA).
AML unit: one or more qualified persons support and advise line managers and executive management, prepare the directives and plan training (Art. 24 AMLO-FINMA); external specialists may be designated under certain conditions (Art. 25 para. 4 AMLO-FINMA).
Risk analysis: the AML risk analysis considers in particular client domicile, client segment and the products and services offered; it is approved by the board or executive management and updated periodically (Art. 25 para. 2 AMLO-FINMA). Firms with five or fewer full-time positions or annual gross revenue below CHF 2 million and a business model without higher risks may limit their AML unit to the tasks in Art. 24 (Art. 75 AMLO-FINMA).
Directives and training: internal directives approved by the board or executive management (Art. 26) and regular training of all staff concerned (Art. 27 AMLO-FINMA).

FINMA expects the risk analysis to work as a real management tool; our article on FINMA Supervisory Notice 04/2026 summarises its expectations. The changes from the AMLA revision and the planned AMLO-FINMA revision are covered in our article on the partial revision of the AMLO-FINMA and the transparency register.

Step by step: due diligence across the client lifecycle

1
Identification
verify the identity of the client and, for legal entities, the signing powers and the persons acting on its behalf.
2
Beneficial owner
obtain the declaration on the beneficial owner and check it for plausibility.
3
Client profile
record the purpose and nature of the relationship, source of assets and expected transactions.
4
Risk classification
apply your criteria for higher risks, screen against sanctions lists and identify PEPs.
5
Approval
obtain the approval required for higher-risk relationships and document additional clarifications.
6
Monitoring and review
monitor transactions and review client records periodically according to risk.
✓
Clarification and reporting
clarify unusual situations promptly and, where the conditions are met, report to MROS.

Checklist

AML directives approved and known to staff
Criteria for higher-risk relationships defined and documented in the risk analysis
Onboarding checklist covering identification, beneficial owner and client profile
PEP and sanctions screening at onboarding and during the relationship
Approval process for higher-risk relationships in place
Annual decision on continuing relationships with foreign PEPs documented
Risk-based schedule for periodic review of client records
Clear responsibility for reports to MROS
Training plan for all staff concerned

How Peak Compliance supports you

Peak Compliance acts as your anti-money laundering unit: we draft directives, review onboarding files and higher-risk relationships, maintain the risk analysis and prepare reports – as part of compliance outsourcing. For your team we offer AML training on site or online. For a first conversation, reach us via the contact page.