SRO & AML Compliance · Zug, Switzerland

Your Swiss AML compliance, handled. From SRO admission to your local AML officer.

We help Web3, crypto and fintech companies from any jurisdiction set up in Switzerland the compliant way. We structure your entry, take you through admission to a FINMA-recognised self-regulatory organisation (SRO) and provide your Swiss-resident AML officer and director, so your team can focus on building.

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Who we work with

  • Virtual asset service providers
  • Token issuers
  • Custody & wallets
  • Exchanges & brokers
  • Payment & fintech

The Swiss requirement

Operating a crypto business in Switzerland means three things.

SRO membership

Financial intermediaries without a FINMA licence must join a FINMA-recognised SRO, such as VQF, PolyReg or SO-FIT, before they start business.

A qualified AML officer

SROs expect a qualified AML officer who knows Swiss AML law. Foreign founding teams rarely have this expertise in-house.

Ongoing supervision

A written AML framework, regular training and an annual AML audit by an accredited audit firm are part of every membership.

What we do

One Zug team for your entire Swiss compliance set-up

From the first assessment to the annual audit, you deal with one contact who knows your business.

01

Regulatory assessment

Is your business model financial intermediation under Swiss AML law, and which route fits you?

  • AMLA qualification of your activities
  • SRO selection: VQF, PolyReg, SO-FIT
  • Roadmap incl. FINMA licence options
  • Formal legal opinions via partner law firms
02

Company set-up & banking

A Swiss entity with the substance SROs and banks look for.

  • Incorporation in Zug
  • Swiss-resident director
  • Bank and crypto-bank account opening
  • Legal and tax advice with our partners
03

SRO admission

We prepare and run your application until you are admitted.

  • Complete application dossier
  • AML directive and business-wide risk assessment
  • Answers to SRO questions and follow-ups
  • Support with an admission audit, if ordered
04 Core service

Local AML officer & deputy

A qualified, Swiss-resident AML officer appointed with your SRO.

  • Officer and deputy coverage
  • Onboarding reviews: risk, PEP, sanctions, adverse media
  • Alert investigations and enhanced due diligence
  • MROS reporting support via goAML
05

Ongoing compliance operations

The day-to-day work that keeps your membership in good standing.

  • KYC/KYB and wallet screening workflows
  • Transaction and blockchain monitoring
  • Travel Rule implementation
  • Board reporting and staff training
06

Audit & regulatory change

Ready for the annual audit and for what comes next.

  • Annual SRO audit preparation and liaison
  • Remediation of audit findings
  • Updates for the revised AML Act
  • Readiness for the planned crypto-institution licence

Hands-on SRO practice. Since submitting a first SRO application to VQF at the end of 2022, our AML officer has served as AML officer or deputy without interruption, completed all required AML training and handled the day-to-day work of KYC, policy updates and reporting.

How it works

Four steps from first call to supervised operations

  1. Assess

    Scoping call, review of your business model and token flows, and a clear Swiss regulatory roadmap.

  2. Structure

    Swiss entity, governance and banking, plus your AML directive, risk assessment and KYC set-up.

  3. Admit

    SRO application, appointment of your AML officer and deputy, and go-live once you are admitted.

  4. Operate

    Ongoing officer mandate, monitoring, training, the annual audit and regulatory updates.

Engagement models

Transparent packages, built around your stage

SRO Launch

Fixed fee

Assessment, AML framework and your complete SRO application through to admission.

AML Officer Mandate

Monthly retainer

Swiss-resident AML officer and deputy, onboarding reviews, monitoring and SRO reporting.

Compliance Care

Annual retainer + effort-based

Regulatory watch, audit preparation, staff training and policy updates.

SRO fees and the accredited auditor's fees are charged separately by the SRO and the audit firm.

Any jurisdiction ⇄ Switzerland

Built as a bridge, now open to every market

We guide companies from many jurisdictions into Crypto Valley. We understand how founders, foreign regulators, investors and Swiss SROs think, and we translate between them.

FAQ

Questions foreign founders ask us

Does my Web3 company need to join an SRO?

Yes, if you carry out financial intermediation under the Swiss AML Act (for example exchange, custody or payment services) and hold no FINMA licence. You must join before you start business. We assess your model first.

Can the AML officer really be outsourced?

Yes, with your SRO's prior approval, a written mandate and an internal person who oversees it. We prepare the mandate and the approval request with you. Some decisions, such as reports to MROS, stay with your company.

Do we need people in Switzerland?

Yes. Every Swiss company needs a director resident in Switzerland, and SROs expect a qualified AML officer and real Swiss substance. We provide both roles as a service: your Swiss-resident director and your AML officer.

What about the planned crypto-institution licence?

The Federal Council has proposed new FINMA licences for crypto-institutions and payment instrument institutions. Depending on your activities, SRO membership may later need to be replaced by a licence. We follow the legislation and plan the transition with you.

SKB Advisors works with Swiss law firms for formal legal opinions. The information on this page is general and does not constitute legal advice.

Planning your Swiss entry? Let's map your SRO route.

Tell us about your business model and home market. We'll come back with a roadmap and a fixed-fee proposal.

info@skbadvisors.ch