Duties at a glance
| Duty | Provision |
|---|---|
| Verifying the identity of the contracting party | Art. 3 AMLA |
| Establishing the beneficial owner | Art. 4 AMLA |
| Special due diligence for higher risks | Art. 6 AMLA |
| Documentation, retention for at least ten years | Art. 7 AMLA |
| Organisational measures, training, controls | Art. 8 AMLA |
| Duty to report | Art. 9 AMLA |
| Supervision and SRO membership | Art. 12, 14 AMLA |
| Federal sanctions measures | Art. 1 EmbA |
What the AMLA means for portfolio managers
- 1Work risk-basedclassify business relationships by risk and clarify those with higher risks in more depth.
- 2Handle PEPs correctlybusiness relationships with foreign politically exposed persons always count as higher risk (Art. 6 AMLA).
- 3Document clearlykeep records so that qualified third parties can form a reliable judgement.
- 4Screen against sanctions listsat onboarding and throughout the business relationship.
- 5Train staff and define controlsso that processes work reliably in daily business.
- ✓Clarify suspicious cases in a structured waydefine clarification, decision and reporting clearly.
How Peak Compliance supports you
- AML competence centre: Peak Compliance handles clarifications, risk analysis and directives as part of compliance outsourcing.
- Sanctions: monitoring and screening of sanctions as an ongoing service.
- AML training: for staff on site or as e-learning – AML and compliance training.
- SRO affiliation: support with AML affiliation – SRO affiliation. Supervision of licensed portfolio managers is explained in the FinIA hub.
- In practice: for example on sanctions and embargoes for Swiss asset managers or the transparency register via EasyGov.
Articles on AML and sanctions
Sanctions & Embargoes: What Swiss Asset Managers Must Consider
The importance of sanctions and embargoes has increased significantly in recent years — also for Swiss asset managers.
Swiss Transparency Register from 1 October 2026: What you should prepare for EasyGov now
Swiss Transparency Register from 1 October 2026: deadlines for portfolio managers and managers of collective assets and how to prepare EasyGov now.
FINMA Modernises Digital Client Identification – What Does This Mean for Asset Managers?
FINMA revises digital client identification rules. What E-ID, QR codes and new security requirements mean for Swiss asset managers.
FATF Country Lists Updated (February 2026): Required Actions for Financial Intermediaries
At its plenary meeting from 11 to 13 February 2026, the FATF updated its country lists. FINMA reminds financial intermediaries to take this into account.
Partial Revision of the AMLO-FINMA, AMLA Revision and Transparency Register
On 12 May 2026, FINMA opened the consultation on the partial revision of the AMLO-FINMA.
FINMA Supervisory Notice 04/2026: AML Risk Analysis
On 4 June 2026, FINMA published Supervisory Notice 04/2026 on AML risk analysis.
Would you like to organise AML prevention and sanctions screening reliably? Talk to us.
At a glance
- Acts: Anti-Money Laundering Act (AMLA, SR 955.0) and Embargo Act (EmbA, SR 946.231).
- Who: financial intermediaries, including portfolio managers, trustees and managers of collective assets.
- Core topics: due diligence, documentation, organisational measures, reporting duty, supervision; implementing sanctions measures.
Frequently asked questions
Which due diligence duties does the AMLA impose?
Financial intermediaries verify the identity of the contracting party (Art. 3 AMLA), establish the beneficial owner (Art. 4 AMLA), clarify unusual transactions and higher risks (Art. 6 AMLA) and document these steps; records are kept for at least ten years (Art. 7 AMLA). Peak Compliance embeds these steps in a clear, risk-based process.
When does the duty to report apply?
Financial intermediaries report immediately to the Money Laundering Reporting Office if they know or have reasonable grounds to suspect that assets are connected with a felony, a criminal organisation or terrorist financing (Art. 9 AMLA). Negotiations broken off for such reasons are also reportable. Peak Compliance supports the clarification and the report in a structured way.
Who joins an SRO, and who is supervised by a supervisory organisation?
Financial intermediaries under Art. 2(3) AMLA join a self-regulatory organisation (SRO) for AML supervision (Art. 12 and 14 AMLA). Portfolio managers and trustees licensed by FINMA are supervised on an ongoing basis by a supervisory organisation under FinIA. Peak Compliance supports both routes.
Why do sanctions matter for portfolio managers?
Based on the Embargo Act, the Confederation imposes coercive measures such as prohibitions, licensing and reporting requirements (Art. 1 EmbA). Portfolio managers therefore screen clients and transactions against the sanctions lists on an ongoing basis. Peak Compliance provides sanctions monitoring and screening.
Does staff need training?
Yes. Financial intermediaries ensure in particular adequate staff training and controls (Art. 8 AMLA). Peak Compliance offers AML training on site or as e-learning.
