Under Article 2 para. 3 of the Anti-Money Laundering Act (AMLA
), financial intermediaries are persons who, on a commercial basis, accept or hold assets belonging to others or who assist in the investment or transfer of such assets. AMLA also cites persons who engage in various activities and services (e.g. credit transactions, services related to payment transactions, money changing and asset management) as examples of financial intermediaries requiring a licence. The details are set out in the Anti-Money Laundering Ordinance FINMA (AMLO
-FINMA) and FINMA Circular 2011/1 "Financial intermediation under AMLA" ("Finanzintermediation nach GwG").
If financial intermediaries, as defined in AMLA, are not members of a self-regulatory organisation (SRO)
, they require authorisation
from FINMA. Directly subordinated financial intermediaries (DSFIs) are also required to request FINMA's approval for any changes
affecting the basis on which authorisation was originally granted. FINMA can also review and order the lifting of supervision
for financial intermediaries under AMLA.