Anti-Money Laundering Requirements for Various Financial Institutions and Businesses

Introduction

The following financial institutions, non-financial businesses, and professions are subject to anti-money laundering (AML) requirements:

1. Banks and Investment Firms

• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

2. E-Money Businesses

• Verify the identity of customers
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

3. Undertakings for Collective Investment

• Market their unit certificates or units
• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

4. Insurance Undertakings

• Identify and verify the identity of customers
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

5. Exchange Offices

• Conduct AML checks on customers
• Verify the identity of customers
• Implement controls to prevent money laundering and terrorist financing

6. Insurance Brokers

• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

7. Payment Service Providers

• Verify the identity of customers
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

8. Asset Management Companies

• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

9. Providers of Certain Services for Legal Entities

• Perform AML duties, including identification and verification of customer identities
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

10. Casinos and Online Gaming Providers

• Identify and verify the identity of customers
• Perform AML duties, including regular risk assessments and implementation of controls to mitigate money laundering risks
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity

11. Lawyers and Law Firms

• Verify the identity of customers
• Perform AML duties, including identification and verification of customer identities
• Implement controls to prevent money laundering and terrorist financing

12. Tax Consultancy Professions and External Bookkeepers

• Identify and verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

13. Real Estate Agents

• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

14. Persons Trading in Goods

• Verify the identity of customers
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

15. TT Service Providers

• Perform AML duties, including identification and verification of customer identities
• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Verify the identity of customers

16. Operators of Trading Platforms for Non-Fungible Tokens

• Identify and verify the identity of customers
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity
• Implement controls to prevent money laundering and terrorist financing

17. Persons Trading or Acting as Intermediaries in Artworks

• Verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

18. Persons Holding Third-Party Assets in Safe Custody

• Identify and verify the identity of customers
• Perform AML duties, including regular risk assessments and implementation of controls to mitigate money laundering risks
• Conduct regular reviews of customer transactions and accounts to detect suspicious activity

Types of Payments or Money Transmission Activities Subject to AML Requirements

The following types of payments or money transmission activities are subject to AML requirements:

All Transactions Involving the Exchange of Legal Tender for Crypto-Assets and Vice Versa

• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Verify the identity of customers
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

Transactions Related to the Use of Crypto-Asset Services

• Identify and verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

Transactions Processed During a Business Relationship that Deviate from the Customer’s Typical Behavior or Profile

• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Verify the identity of customers
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

Transactions Suspected of Being Connected to Money Laundering, Predicate Offenses of Money Laundering, Organized Crime, or Terrorism

• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Verify the identity of customers
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity

Exceptions

The following exceptions may apply in certain cases:

Small Transactions Below a Certain Threshold (CHF 10,000)

• May be exempt from AML requirements
• Verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

Transactions Between Individuals Who Have a Pre-Existing Relationship and Can Be Identified Through Other Means

• May be exempt from AML requirements
• Identify and verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks

Certain Types of Transactions or Activities that Are Exempt from AML Requirements

• Verify the identity of customers
• Conduct regular risk assessments and implement controls to mitigate money laundering risks
• Perform AML duties, including regular reviews of customer transactions and accounts to detect suspicious activity