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Directly subordinated financial intermediaries (DSFI)

Under Article 2 para. 3 of the Anti-Money Laundering Act (AMLA; SR 955.0), financial intermediaries that are not affiliated to a self-regulatory organisation (Art. 14 para. 1 AMLA) require a licence from FINMA in order to conduct their activities.

Under Article 2 para. 3 AMLA financial intermediaries are persons who, on a professional basis, accept or hold deposit assets belonging to others or who assist in the investment or transfer of such assets. The AMLA also cites as examples of financial intermediaries requiring a licence persons who engage in various activities and services such as credit transactions, services related to payment transactions, trade in banknotes and coins, foreign exchange, precious metals, commodities and in their derivatives, asset management, investments made as investment advisors and the holding on deposit and management of securities.

Further details as to when the Professional Practice of Financial Intermediation is subject to supervision can be found in the Ordinance on the Professional Practice of Financial Intermediation (OPPFI; SR 955.071) and FINMA Circular 2011/1 Financial Intermediation under AMLA (in German, French and Italian).

Licencing requirements are specified in Article 14 para. 2 AMLA. Here it is set down that applicants for licences must be registered in the commercial register, ensure compliance with AMLA obligations by having an appropriate organisational structure and internal regulations in place, and be of good repute, as must also be those persons entrusted with management and executive management tasks in order to comply with the AMLA requirements for proper business conduct.

To be authorised as a Directly subordinated financial intermediaries (DSFI), applicants must comply fully with the licencing requirements defined by law. Authorised DSFI are also obliged to adhere to the underlying licensing conditions on an ongoing basis. Moreover, applicants must immediately report any serious occurrences that are of relevance to its supervision (Art. 29 para. 2 FINMASA). This means that FINMA must be immediately informed about any changes made to the data contained in the original application or about any changes concerning the licencing requirements.

Applications must demonstrate that any future licence holders have fulfilled all the licencing requirements specified in the Anti-Money Laundering Act or will do so immediately after authorisation has been granted.

Financial intermediaries submitting an application under Article 14 para. 2 AMLA should use the FINMA application form ‘Licence applications for DSFIs’ (in German, French and Italian). Please send the completed application form and the enclosures requested to:

Swiss Financial Market Supervisory Authority FINMA
Markets Division
Directly subordinated financial intermediaries Section
Laupenstrasse 27
3003 Bern

Applications must be submitted in one of Switzerland's main official languages (German, French or Italian) and be signed by the applicant. Applications filed by the applicant’s legal representative must be signed by said person; a copy of the document granting power of attorney must also be included.

FINMA can only process formally complete applications. If necessary, the applicant may be requested to submit further information or documents to examine full compliance with the licensing requirements.

An application fee is charged to the applicant regardless of the outcome of the application. Even if the application could not be processed for specific reasons (e.g. lack of cooperation, missing documentation) and authorisation is not granted, the applicant must pay an application processing fee. The fee charged is in accordance with the FINMA Ordinance on the Levying of Supervisory Fees and Duties (FINMA-GebV; SR 956.122).

The templates provided below serve to facilitate the preparation of applications. They are available in German, French and Italian.

The application form "Licence applications for DSFIs", standard declaration forms and a list of authorised audit companies are listed below:

Reporting to the Money Laundering Reporting Office Switzerland (MROS)

  • Checklist in the event of suspected money laundering or terrorist financing

Supervisory fees 2013