Overview
Financial Regulation & Licensing
The full picture: FINMA licences, SRO membership and AML in one place, and how to tell which you need.
Financial Regulation overviewSRO membership in
Switzerland
If you handle other people’s money as a business but do not need a prudential FINMA licence, Swiss law still puts you under anti-money-laundering supervision. This catches crypto and token businesses, virtual-asset service providers (the EU calls them CASPs), payment and e-money providers, and money-service or escrow operators. The route is affiliation with one of the eleven FINMA-recognised Self-Regulatory Organisations. We confirm whether the duty applies, build the AML framework, choose the right SRO and carry you through admission.
At a glance
The anti-money-laundering route for crypto, payment, token and money-service businesses.
An AML affiliation, not a prudential licence, granted by a private body that FINMA recognises and oversees.
- Legal basis
- AMLA, Art. 14
- Who it applies to
- Professional financial intermediaries
- Recognised SROs
- 11 (FINMA, June 2026)
- Typical timeline
- 2–4 months once the file is ready
- Ongoing
- Annual AML audit
Start here
Three Swiss gates — and which one is yours
Before anything else, settle which regulatory gate your business goes through; the wrong door costs months. Switzerland supervises money-handling businesses through three of them. Two are prudential licences, granted and supervised by FINMA itself. The third is an SRO affiliation: an anti-money-laundering membership with a private body that FINMA recognises, not a licence. This page is about that third gate.
Gate 3 · AMLA, not prudential
SRO affiliation — this page
An AML membership FINMA recognises and oversees
For professional financial intermediaries that hold or move other people’s money but need no prudential licence: most crypto, payment, token and money-service businesses. You affiliate with one of the eleven FINMA-recognised Self-Regulatory Organisations (such as VQF), which issues binding AML rules and audits your compliance.
Gate 1 · prudential
Direct FINMA licence
Authorised and supervised by FINMA itself
For deposit-taking and banking, fund management, securities-firm and DLT-trading activity, including the FinTech licence under art. 1b Banking Act. A prudential authorisation to carry on the activity: a heavier gate than an SRO.
Gate 2 · prudential
FinIA licence + Supervisory Organisation
Licensed by FINMA, supervised by an SO
For portfolio (asset) managers and trustees. Since 2020 they hold a FinIA licence and are supervised by a Supervisory Organisation (SO), not an SRO. The common confusion: managing clients’ money is Gate 2, not Gate 3.
Two things sit alongside the gates. Insurance has its own route: undertakings are authorised under the Insurance Supervision Act and intermediaries entered in FINMA’s register. And some activities, notably consumer-credit lending and broking, also need a cantonal permit under the Consumer Credit Act (KKG) on top of any federal gate. If you only advise, or never touch your customers’ money, you may be outside the net altogether; the check further down tells you which.
The legal trigger
Who must affiliate, and when
A Self-Regulatory Organisation (SRO) is a private body, recognised and supervised by FINMA, that admits and audits financial intermediaries for anti-money-laundering purposes under the Anti-Money Laundering Act. If your business accepts, holds or helps transfer assets belonging to others on a professional basis, and you do not hold a prudential FINMA licence, you must affiliate with an SRO before you operate. There are eleven recognised SROs as of June 2026, and choosing between them is worth getting right.
When the activity is “professional”
The duty only bites once the activity is carried on professionally. The Anti-Money Laundering Ordinance sets de-minimis thresholds: gross profit above CHF 50,000 a year, business relationships with more than 20 contracting parties in a year, unlimited power of disposal over third-party assets above CHF 5 million at any time, or transactions exceeding CHF 2 million in a calendar year. Crossing any single threshold makes the activity professional and triggers affiliation.
Why there is no alternative since 2020
Until the end of 2019, a financial intermediary could choose to be supervised for anti-money-laundering directly by FINMA (the “directly-subordinated” or DSFI status). The FinSA/FinIA reform abolished that route on 31 December 2019. Since 1 January 2020, SRO affiliation is the only way for a non-prudentially-licensed intermediary to meet its AML duties. For the businesses on this page, it is not one option among several but the route.
Scope
What you can run under an SRO
An SRO covers a wide band of money-handling models, subject to a written activity analysis. Similar-sounding services can sit on opposite sides of the line depending on custody, discretion and the character of the instrument, so the list below is the starting point, not the ruling.
SRO affiliation: AML only
Activities an SRO covers
- Money & value transfer: remittance, payment transmission and processing of third-party funds.
- Issuing means of payment: prepaid cards, e-money, payment tokens and vouchers redeemable with third parties.
- Crypto exchange & custody: fiat↔crypto and crypto↔crypto exchange, wallet custody and token transfers for clients, below the DLT-facility and securities perimeter.
- Foreign exchange & money changing: bureau de change and professional FX dealing.
- Commercial lending & financing: non-bank credit, factoring and financial leasing (consumer credit adds a cantonal KKG permit).
- Dealing for third parties: banknotes and coins, money-market instruments, precious metals, commodities and securities, short of a licensed securities firm.
- Safekeeping & administering assets: holding or administering securities and assets for clients where AMLA applies.
Interactive check
Do you need an SRO? Run the check.
Pick the plain description that fits your business. Two or three simple questions, then we tell you the likely route. No jargon, no legal advice. The binding answer always comes from a written review.
Step 1
The short version. If your business handles other people’s money (sending or processing payments, letting people buy/sell/hold crypto, changing money, holding funds or assets, or lending), and you do not hold a full FINMA licence, you most likely need to join an SRO (an anti-money-laundering body recognised by FINMA). If you invest or manage money for clients, run a fund, or take deposits, you need a FINMA licence instead. If you only give advice or use your own money, you may need neither. Tell us what you do and we’ll confirm the route.
Choosing a body
The eleven FINMA-recognised SROs
All eleven apply the same federal law, but they differ in sector focus, working language and location. Several are sector-specific; four (VQF, PolyReg, ARIF and SO-FIT) admit the broad range of parabanking intermediaries, which is where most crypto, payment and fiduciary businesses affiliate.
| SRO | Typical members | Contact |
|---|---|---|
VQFZug
|
Broadest membership, including crypto and fintech; the largest SRO. | General-Guisan-Strasse 6, 6300 Zug +41 41 763 28 20 info@vqf.ch vqf.ch |
PolyRegZurich
|
General financial intermediaries; tech-neutral, suits hybrid fiat-and-crypto models. | Florastrasse 44, 8008 Zürich +41 44 500 36 40 info@polyreg.ch polyreg.ch |
ARIFGeneva
|
French-speaking Switzerland; broad membership, fintech-friendly. | Rue de Rive 8, 1204 Genève +41 22 310 07 35 info@arif.ch arif.ch |
SO-FITGeneva
|
Financial intermediaries and trustees in the Geneva region. | Rue Pedro-Meylan 2, 1208 Genève +41 22 700 73 20 info@so-fit.ch so-fit.ch |
AOOSZurich
|
Supervision body also recognised as an SRO. | Clausiusstrasse 50, 8006 Zürich +41 44 215 98 98 info@aoos.ch aoos.ch |
SRO-Treuhand SuisseBern
|
Members of the Treuhand Suisse fiduciary association. | Monbijoustrasse 20, 3011 Bern +41 31 380 64 30 info@treuhandsuisse.ch treuhandsuisse.ch |
OAD FCTLugano
|
Ticino fiduciaries and intermediaries (Italian-speaking). | oadfct.ch |
SRO SAV/SNVBern
|
Lawyers and notaries (Bar Association & Notaries). | sro-sav-snv.ch |
SRO-SVVZurich
|
Life insurers (Swiss Insurance Association). | sro-svv.ch |
SRO SLVZurich
|
Leasing companies (Swiss Leasing Association). | leasingverband.ch |
SRO SVIGBaar
|
Investment companies (Verband der Investmentgesellschaften). | svig.ch |
For most internationally-owned crypto, payment and asset-holding businesses the realistic choice narrows to VQF, PolyReg, ARIF or SO-FIT. We match the SRO to the activity, language and risk profile rather than defaulting every client to the same one, or you can approach a body directly using the details above.
What you need
Minimal set-up in Switzerland
Affiliation attaches to a real Swiss entity with genuine substance, not a letterbox. Five things have to be in place before an SRO will admit you:
- A Swiss-domiciled board, properly educated and experienced.
- An AML Manager (MLRO) (an external one is accepted) with the right experience and training.
- A recognised external auditor and an AML policy suite covering KYC, beneficial owners, PEP and sanctions screening, source of funds and wealth, monitoring, reporting and record-keeping.
- A Swiss company (AG or GmbH) set up for the relevant activities.
- A registered office, a working website and a landline: the visible signs of real presence.
How it runs
From assessment to admission
A five-phase, deliverable-driven process. The work is front-loaded into the AML framework; once that file is sound, admission is comparatively quick: two to four months from a ready framework, as of June 2026. The variable is the quality of the file, not the SRO. Per-step timings are indicative and often overlap.
- 1–2 weeks
Scoping & lane selection
Business-model assessment and written qualification across the FINMA licence categories and the SRO/AMLA framework, including selection of an appropriate SRO.
- 2–4 weeks
Swiss entity & people
Registered seat, board signatory and MLRO, auditor nomination, outsourcing controls, and interaction with the Supervisory Organisation where FinIA applies.
- 3–6 weeks
Policy suite & evidence
AML/KYC, sanctions screening, transaction monitoring and record-keeping; onboarding documentation and a training plan; consistency across SRO, FINMA registers and the website.
- 2–4 months
Filing & reviewer interactions
Preparation of the SRO admission (or FINMA licence) dossier; handling of regulator queries; alignment of client-facing materials with the applicable framework.
- Ongoing
Go-live & audit support
Operational integration and KPI reporting to the board; pre-audit reviews ahead of the initial and subsequent SRO/AMLA audit cycles; the first AML audit falls within the first year.
Budget
What it costs
There are two layers. The first is the SRO’s own schedule: an admission fee plus a recurring annual fee, with file- or turnover-based components on top. VQF, the largest SRO, publishes an admission processing fee of about CHF 1,800 and a minimum annual fee in the region of CHF 1,250 (as of June 2026); file-based fees run in tiers of roughly CHF 30, 20 and 10 per file, and turnover-based fees range from about CHF 500 to CHF 10,000. An external AML audit, charged by time, sits on top each year. These are VQF’s published figures as of June 2026; each SRO sets its own tariff, so the exact numbers turn on which body you join.
The second layer is standing up the firm and the AML framework. For a crypto or payment business, first-year costs commonly run to CHF 50,000–150,000 once company set-up, the framework, admission, the first audit and advisory are counted. We quote a fixed advisory budget against a confirmed activity, so the number is settled before any work begins.
Ask for a fixed budget
After admission
Ongoing obligations of a member
Affiliation is not a one-off filing. As a member you carry continuing anti-money-laundering duties, which the SRO audits:
- a written AML risk analysis, kept current as the business changes;
- internal directives covering onboarding, due diligence and the identification of beneficial owners;
- risk-based transaction monitoring and the clarification of unusual activity;
- a designated AML compliance officer and trained staff;
- complete records, retained for the statutory period;
- reporting of well-founded suspicion to MROS, and an annual audit by an SRO-accredited auditor.
When an SRO is the wrong gate
If the activity is really managing third-party portfolios, running a fund or taking deposits, you need a FINMA licence: back to Gate 1 or Gate 2 above, not an SRO. If your crypto or payment activity will fall under the 2027 Crypto-Institution or Payment Instrument Institution categories, an SRO affiliation may be only an interim step before a direct FINMA licence. We say which gate you are in before you spend on a framework you do not need.
Why Goldblum
AML and SRO affiliation in practice
Two things decide whether an SRO affiliation goes well: scoping the right route before any cost is committed, and carrying the AML function long after the certificate arrives. We have done both since 2014.
10 yrs
Recognised by IFLR1000
IFLR1000, a leading international directory of financial and corporate practices, has recognised us for a decade for banking, finance and regulatory work.
Day one
Finance-first scoping
We analyse the model under AMLA, FinIA, FinSA and the Banking Act before launch, so the route (SRO or a FINMA licence) is settled from the outset, not discovered later.
Ongoing
We stay after admission
We can act as your external AML Officer (MLRO), run the periodic audits and keep the framework current. Licensing is the start of the relationship, not the end.
Beyond licensing — how we stay with you
External AML Officer (MLRO)
Serving as your outsourced AML Officer under mandate: red-flag escalation, the SAR/MROS process, and reporting to the board.
Periodic audits
Preparation and coordination with the auditor or SRO, development of remediation plans, and follow-up through to close-out.
Client documentation
Onboarding and conduct materials: KYC questionnaires, source-of-funds and wealth declarations, PEP and sanctions notices, risk warnings, fee disclosures, terms and engagement letters.
Regulatory correspondence
Drafting and managing responses to FINMA or the SRO, submission of notifications and updates, and assistance with bank or PSP due-diligence requests.
Training & refreshers
Induction and periodic AML training, attendance tracking, short assessments, and role-based modules for front office, operations and management.
Controls & registers
Outsourcing register, a roles-and-responsibilities matrix, monitoring checklists, and a documented audit trail of file reviews and remedial actions.
Track record
SRO and FINMA engagements since 2014
Non-confidential mandates from more than a decade of Swiss financial-regulation work, dating back to 2014: SRO affiliations, FINMA and FinIA licensing, and regulatory enquiries across crypto, payments, asset management and token projects.
SRO authorisation · FINMA non-subordination ruling
FinIA licence
SRO authorisation · FINMA non-subordination ruling
SRO authorisation · FINMA non-subordination ruling
SRO authorisation · FINMA non-subordination ruling
SRO affiliation
SRO affiliation
SRO affiliation
SRO affiliation
SRO affiliation
- OTN Blockchain StiftungSwiss foundation · federal authorisation
Listed with each client’s agreement (non-NDA). Engagement details are kept general; specifics are covered by professional confidentiality.
Related
Next in this practice
Talk to us
Check your route first
Tell us the activity and we say which gate applies (SRO, a FINMA licence, or neither) before you spend on a framework.
Request an assessment
FAQ
SRO membership in Switzerland: FAQ
01Who must join an SRO in Switzerland?
A financial intermediary that acts on a professional basis and does not hold a FINMA prudential licence must join one of the 11 FINMA-recognised SROs. Under Article 2 paragraph 3 and Article 14 of the Anti-Money Laundering Act, that covers anyone who accepts, holds or helps transfer assets belonging to others as a business: crypto exchanges and brokers, payment and money-transmitting firms, currency dealers, and lenders, leasing and factoring providers. Affiliation must be in place before the activity starts.
02How many SROs are recognised by FINMA?
Eleven, as of June 2026: AOOS, ARIF, OAD FCT, PolyReg, SRO SLV (Swiss Leasing Association), SRO SAV/SNV (Bar and Notaries), SRO-SVV (Insurance Association), SRO SVIG (Investment Companies), SO-FIT, SRO-Treuhand Suisse and VQF. FINMA recognises and supervises each of them; several are sector-specific, while VQF, PolyReg, ARIF and SO-FIT admit the broad range of parabanking intermediaries, including crypto and fintech.
03When did SRO membership become the only AML route?
On 1 January 2020. The FinSA/FinIA reform abolished the former directly-subordinated status (DSFI/DUFI) under which a financial intermediary could be supervised for anti-money-laundering purposes by FINMA directly; that route ended on 31 December 2019. Since then, a professional financial intermediary without a prudential licence has only one option: affiliation with a recognised SRO.
04What counts as acting on a professional basis?
The Anti-Money Laundering Ordinance sets de-minimis thresholds. Activity is professional if, for example, gross profit exceeds CHF 50,000 a year, you maintain business relationships with more than 20 contracting parties in a year, you hold unlimited power of disposal over third-party assets above CHF 5 million at any time, or you move transactions of more than CHF 2 million in a calendar year. Crossing any single threshold triggers the affiliation duty.
05How long does SRO affiliation take?
Two to four months, measured from the point the AML framework is ready rather than from the first conversation. The time goes into the risk analysis, internal directives, onboarding procedures and the appointment of an AML officer; once that file is complete, the SRO admission review itself is comparatively quick. A weak or generic AML file is the usual cause of delay.
06What does SRO membership cost?
There are two layers. The SRO charges an admission fee and a recurring annual fee. VQF, for example, publishes an admission processing fee of about CHF 1,800 plus a minimum annual fee in the region of CHF 1,250, with file- or turnover-based components on top. Separately, standing up the company and the AML framework for a crypto or payment business commonly brings first-year costs to CHF 50,000–150,000 once admission, the first audit and advisory are counted. We quote a fixed advisory budget against a confirmed activity.
07Is SRO membership the same as a FINMA licence?
No. A FINMA licence is a prudential authorisation to carry on a regulated financial activity: managing client portfolios, running a fund, taking deposits. SRO membership is an anti-money-laundering affiliation for intermediaries that do not need a prudential licence. The SRO is a private body, itself recognised and supervised by FINMA. Some businesses need a licence, some need only SRO membership, and a few need both.
08Do crypto firms need SRO membership or the 2027 licence?
As of June 2026, a crypto business doing exchange, brokerage or transfer on a professional basis joins an SRO for AML purposes; that is the current route. The reform expected in 2027 adds a dedicated Crypto-Institution licence for custody, trading and staking and a Payment Instrument Institution licence for stablecoins and payments, both supervised by FINMA directly. Where your activity will fall under the new categories, SRO membership can be an interim step, so we structure for both.
09Do I need a Swiss company to join an SRO?
In almost all cases, yes. SRO membership attaches to a Swiss legal entity with a real presence: an office and qualified people here. We incorporate the company, arrange the substance and open banking as part of the same project, so the affiliation rests on a properly constituted Swiss entity rather than a shell.
10Which SRO should a crypto or fintech business choose?
Four SROs (VQF, PolyReg, ARIF and SO-FIT) admit the broad range of parabanking intermediaries and are the usual homes for crypto, payment and fintech models; the other seven are sector-specific (leasing, insurance, notaries, investment companies). The right choice turns on your activity mix, working language and where supervision sits most comfortably for your model, not on price alone. We match the SRO to the business and run the affiliation through to admission.
Not sure if your activity needs an SRO?
Send us a two-line description of what the business does. A partner confirms whether it is financial intermediation on a professional basis, and which of the 11 SROs fits, before you commit to anything.