SRO or supervisory organisation: who is responsible?
Responsibility depends on the activity. The overview below provides clarity:
| Activity | Supervision | Legal basis |
|---|---|---|
| Financial intermediary under Art. 2 para. 3 AMLA (e.g. lending, payment services, trading in foreign exchange, precious metals or securities) | Self-regulatory organisation (SRO), for AMLA duties only | Art. 12(c) and Art. 14 AMLA |
| Portfolio managers and trustees (Art. 17 FinIA) | FINMA licence; ongoing supervision by a supervisory organisation (SO), including AMLA duties | Art. 43a FINMASA |
| Managers of collective assets (Art. 24 FinIA) | FINMA directly | Art. 12(a) AMLA |
For portfolio managers who require a licence, the relevant route is therefore the FINMA licence rather than SRO affiliation. Peak Compliance supports that route under licensing for portfolio managers.
How does SRO affiliation work with Peak Compliance?
- 1Clarify the regulatory statusPeak Compliance maps your activity to the AMLA and identifies the competent supervisor.
- 2Choose the SROSROs may focus affiliation on specific fields of activity. Peak Compliance shows which SRO fits your business model.
- 3Build the organisationPeak Compliance drafts the internal anti-money laundering policies and describes an organisation that ensures AMLA compliance.
- 4File the applicationPeak Compliance compiles a complete file and supports the application until the SRO decides.
- ✓Ongoing complianceafter affiliation, Peak Compliance can run the anti-money laundering unit, sanctions screening, staff training and preparation for the SRO audit.
Peak Compliance supports applications to SROs recognised by FINMA; FINMA publishes the current list.
What belongs in the application?
Each SRO sets its exact requirements in its regulations. Peak Compliance compiles the documents that are usually requested:
- Articles of association, commercial register extract and a description of the business
- Organisation chart and a description of the organisation
- Internal policies on anti-money laundering and due diligence
- Information on the responsible persons and qualified shareholders
- Designation of the anti-money laundering unit and a staff training concept
Where a group structure or foreign shareholders are involved, Peak Compliance clarifies with the SRO in advance which additional information is required.
A complete and well-structured file lays the foundation for a timely SRO decision.
Legal basis
- Art. 2 AMLA: para. 3 defines financial intermediaries who, on a professional basis, accept, hold on deposit or help invest or transfer assets belonging to others.
- Art. 14 AMLA: duty to join an SRO; right to affiliation where internal rules, organisation and reputation are adequate.
- Art. 12 AMLA: FINMA for financial intermediaries under para. 2; recognised SROs for intermediaries under para. 3 and for advisers.
- Art. 8 AMLA: organisational measures, in particular adequate staff training and controls.
- Art. 43a FINMASA: supervisory organisations for portfolio managers and trustees.
- FINMA overviews: self-regulatory organisations and supervisory organisations.
English versions of Swiss federal law are provided for information only; the German, French and Italian texts are authoritative. Links to Art. 2, 12 and 14 AMLA point to the current consolidated German text.
Roles and scope
- SRO: decides on affiliation and audits compliance with AMLA duties.
- Financial intermediary: remains responsible for meeting its due diligence obligations.
- Peak Compliance: prepares the application, builds the organisation and, on request, performs the ongoing AML tasks.
- Separate service: FINMA and FMA licences, which Peak Compliance supports under FINMA and FMA licensing.
Why Peak Compliance
- Anti-money laundering expertise: Peak Compliance runs AML units, including onboarding reviews, remediation projects and reviews supported by specialised IT tools.
- Clear allocation of responsibilities: cooperation with the supervisory organisations AOOS and OSFINcontrol and experience with licensing procedures before FINMA and the FMA.
- One point of contact: from the application to compliance outsourcing and AML training.
- Insights on the 2026 AMLA revision and the FINMA guidance on AML risk analysis.
Clarify your SRO affiliation with Peak Compliance: book a free initial consultation via the contact page.
At a glance
| Who it is for | Financial intermediaries under Art. 2 para. 3 AMLA that do not hold a FINMA licence |
| What | Support with the SRO affiliation application; afterwards, on request, the anti-money laundering unit, policies and training |
| How | Strategic and operational support; templates for policies and organisation; coordination with the SRO |
| When | Before starting the activity or when the business model changes |
| Pricing | Proposal after reviewing the business model; ongoing services according to the agreed scope |
Frequently asked questions
Who has to join an SRO in Switzerland?
Financial intermediaries under Art. 2 para. 3 AMLA – those who, on a professional basis, accept, hold on deposit or help invest or transfer assets belonging to others – must join an SRO (Art. 14 para. 1 AMLA). Examples include lending, payment services and trading in foreign exchange, precious metals or securities. Following the AMLA revision, certain advisers are covered as well.
How does an SRO differ from a supervisory organisation (SO)?
An SRO supervises financial intermediaries under Art. 2 para. 3 AMLA solely with regard to their anti-money laundering duties. A supervisory organisation under Art. 43a FINMASA supervises FINMA-licensed portfolio managers and trustees on an ongoing basis under the financial market acts. Portfolio managers under Art. 17 FinIA therefore need an SO, not an SRO affiliation.
What are the requirements for affiliation?
The intermediary needs internal rules and an organisation that ensure compliance with AMLA duties, and it and the responsible persons must enjoy a good reputation (Art. 14 para. 2 AMLA). SROs may set additional requirements in their regulations. Peak Compliance prepares the documentation so that it demonstrates these requirements clearly.
How does Peak Compliance help after affiliation?
On request, Peak Compliance runs the anti-money laundering unit, sanctions screening, policies and annual staff training. The intermediary thus meets its ongoing AMLA duties and is well prepared for the SRO audit.
Sources
- Anti-Money Laundering Act (AMLA), Art. 14 – Affiliation to a self-regulatory organisation (German text)
- Anti-Money Laundering Act (AMLA), Art. 2 – Scope (German text)
- Anti-Money Laundering Act (AMLA), Art. 12 – Supervisory responsibility (German text)
- Financial Market Supervision Act (FINMASA), Art. 43a – Supervisory organisation
- FINMA – Self-regulatory organisations (SROs)
- FINMA – Supervisory organisations (SOs)
