FinIA: one Act, five licences, two supervisors

Regulatory analysis · Switzerland

The Financial Institutions Act of 15 June 2018 (FinIA) has been in force since 1 January 2020. One statute licenses five categories of non-bank financial institution, splits their supervision between FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. and a private layer of supervisory organisations, and — through its Annex — rewired the Anti-Money Laundering Act on its way in. A pending amendment would add two more licence categories and pull roughly 200 crypto firms out of the self-regulatory channel; that file has produced nothing official since its consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules. closed on 6 February 2026.

Below: the architecture as it stands in the in-force text, what six years of licensing practice have produced by FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s own numbers, where the financial-crime pressure points sit, and what the amendment would do to each of them.

This dossier covers the Act. The draft amendment's crypto provisions are analysed clause by clause in The Swiss crypto licence; the question of whether SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. supervision of crypto firms satisfies FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s standard has its own dossier, Supervised by whom.

One Act, five licences

FinIA governs financial institutions "irrespective of their legal form" (Art. 2 para. 1). Five categories, each with its own definition and its own capital floor:

Three structural rules do most of the work:

Commerciality is the trigger. The Act applies to activity pursued as "an independent economic activity pursued on a permanent, for-profit basis" (Art. 3). The ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act.-level thresholds sit in the Financial Institutions Ordinance (FinIO, SR 954.11).

The de-minimis line inside asset management. A manager of collective assets whose funds are for qualified investors and stay within Art. 24 para. 2 — in the main variant, CHF 100 million including leverage — is a portfolio manager, not a manager of collective assets. The category, and with it the supervisor, moves with assets under management.

The authorisation chain (Art. 6). The licences nest: a banking licence carries authorisation to act as securities firm, manager of collective assets, portfolio manager and trustee; a securities-firm licence under Art. 41 let. a carries the three below it; a fund management licence carries manager of collective assets and portfolio manager; a manager-of-collective-assets licence carries portfolio manager. Nothing cascades upwards, and nothing cascades into the trustee licence except from bank and securities firm.

Outside the perimeter entirely (Art. 2 para. 2): purely intra-family and employee-scheme management, lawyers and notaries acting under professional secrecy, statutory mandates, the SNB and BIS, pension institutions, insurers, and banks — each governed elsewhere.

Authorisation comes from FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. in every category (Art. 5 para. 1), and a financial institution may only be entered in the commercial register once it has it (Art. 5 para. 2).

The two-layer supervisory architecture

FinIA's most distinctive design choice is that licensing and supervision run on different rails for the two smallest categories.

Managers of collective assets, fund management companies and securities firms are supervised by FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. directly (Art. 61 para. 3). Portfolio managers and trustees are licensed by FINMA but their ongoing supervision is performed by a supervisory organisation — a private body, itself authorised and supervised by FINMA under Title 3 of the Financial Market Supervision Act (Arts 43a–43l FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG.). An applicant portfolio manager or trustee must prove it has an SO before FINMA will license it (Art. 7 para. 2 FinIA).

The SO's mandate under Art. 43b FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG. is continuous monitoring of compliance with "the financial market legislation" — which for a portfolio manager includes its anti-money-laundering duties, since FinIA's Annex made portfolio managers and trustees prudentially supervised financial intermediaries under Art. 2 para. 2 let. a^bis AMLA. Where an SO finds violations, it sets a deadline to restore compliance; if the deadline passes, it informs FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. (Art. 43b para. 2 FINMASA). Enforcement remains FINMA's alone — an SO has no power to fine, ban or publish.

The SO population is consolidating. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. authorised the first supervisory organisations on 6 July 2020. Five operated until late 2025. On 27 November 2025 FINMA approved the merger of FINcontrol Suisse AG with OSFIN, the merged entity to carry the name OSFINcontrol AG — on FINMA's own announcement, the second-largest SO. FINMA's list of authorised supervisory organisations, generated 29 August 2026, now shows four: AOOS, OSIF, OSFINcontrol AG and SO-FIT. FINMA's 2025 Annual Report records that two SOs had their audits pushed back to 2026 "owing to the ongoing merger process".

Two of the four wear two hats. FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG. expressly permits an SO also to act as a self-regulatory organisationA private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist in Switzerland. under the AMLA, provided the dual role "is evident to others at all times" (Art. 43a paras 3–4). Comparing FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s two registers as generated on 29 August 2026, two names appear on both the SO list and the list of eleven recognised SROsA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.: AOOS and SO-FIT. The same body may therefore supervise a licensed portfolio manager in one capacity and an SRO-affiliated money remitter in the other — the statute requires the capacities to be distinguishable, not the staff (Art. 43e para. 5 FINMASA).

Audit cadence is a diligence data point. The default is an annual audit, but the SO may stretch the cycle to a maximum of four years by reference to the firm's activity and risks (Art. 62 para. 2 FinIA); in the off years the firm files a standardised self-report (Art. 62 para. 3). Two portfolio managers can therefore sit on very different scrutiny cycles while holding the same licence — worth asking about when assessing a Swiss counterparty.

How the escalation channel ran in 2025. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s Annual Report 2025 reports 35 notifications filed by SOs, of which 21 led to further investigation or intensive supervision by FINMA; the remainder were referred back to the SOs on the ground that their own supervisory measures were not yet exhausted. The primary problem areas FINMA names are adequate organisational structures, proper business conduct, FinSA rules of conduct, capital requirements — and combating money laundering. The same report records shortcomings FINMA identified at the SOs themselves: supervisory audit reports taking up to ten months to process, or not processed until after the following year's audit, with findings not consistently followed up. FINMA states that it has required the SOs to establish clear processes for acting on audit findings promptly.

Fit and proper, as the Act builds it

Art. 11 FinIA is the Act's fit-and-proper provision, and it operates at three levels:

• The institution and its managers. The financial institution and the persons responsible for its administration and management must provide a guarantee of irreproachable business conduct; the individuals must additionally enjoy a good reputation and hold the specialist qualifications their function requires (paras 1–2).
• The owners. Qualified participants — 10% of capital or votes, or significant influence by other means — must enjoy a good reputation and ensure their influence is not detrimental to prudent and sound business activity (paras 3–4). Acquisitions and disposals crossing 20%, 33% or 50% are notifiable in advance (para. 5); FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. may suspend the voting rights of a qualified participant to enforce these provisions (Art. 65).
• The carve-outs for the small end. Portfolio managers and trustees are exempt from the participation-notification duties, and their qualified participants are expressly permitted to hold management roles (paras 7–8) — the owner-managed firm is the category's normal case, and the statute accommodates it.

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s 2025 Annual Report describes its current working formulation: the guarantee requirement is made up of "professional suitability for the specific function sought (fitness) and integrity (properness)". The same report carries the instructive case for this practice's readers: an in-depth review of an independent portfolio manager's licence application "revealed serious shortcomings with regard to combating money laundering", upon which the applicant withdrew the application and applied to wind up the licensable activity — with FINMA monitoring the wind-down to completion. An AML failure surfaced as a fit-and-proper failure, at the gate rather than after it.

The churn behind the register is substantial: 4,752 change requests from portfolio managers and trustees in the three years since the transition ended — around 150 a month — primarily concerning changes to the persons responsible for proper business conduct and to organisational documents. A licence checked once is a licence out of date.

Six years in, by FINMA's own numbers

The 2020 transition ran on Art. 74: firms already authorised under another financial market act needed no new licence (para. 1); firms newly caught had six months to report to FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. and three years — to the end of 2022 — to file an application, continuing to trade in the meantime provided they held SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. affiliation (para. 2). That bridge mechanism matters beyond history, because the pending amendment copies it.

The licensing wave, per FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s Annual Report 2025 (figures to end-2025):

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. attributes the long tail of pending transition-era applications — about 3% of the 1,699 received in the first three years — to complexity, slow applicant feedback and "in-depth investigations concerning the proper business conduct of the persons responsible".

For scale at the other end of the Act: six institutions hold the fintech licence under Art. 1b of the Banking Act on FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s list generated 29 August 2026 — the category the pending amendment would repeal and replace. The fintech licence sits in the Banking Act, not FinIA; the amendment would fold its successor into FinIA as a sixth category.

What FinIA did to the AML system

FinIA's Annex is easy to overlook and did the heavier financial-crime work. Three changes, all in force since 1 January 2020:

Portfolio managers and trustees became prudentially supervised AML intermediaries. Art. 2 para. 2 let. a^bis AMLA lists them alongside banks. Their AML supervision travels with their prudential supervision — FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. is the responsible authority under Art. 12 let. a AMLA, with the ongoing work performed through the SO channel described above.

The direct-subordination route was abolished. Before 2020, a parabankingThe Swiss term for financial businesses that are not banks — money changers, money transmitters, crypto firms, trustees. They are supervised by SROs, not by FINMA. intermediary under Art. 2 para. 3 AMLA could choose direct FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. supervision for AML purposes (the "DSFI" route) instead of joining an SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.. FinIA's Annex removed the choice: Art. 14 AMLA now requires every Art. 2 para. 3 intermediary to affiliate to a recognised SRO, and Art. 12 let. c AMLA gives the SROs alone the supervisory responsibility for that population. A trap survives in older FINMA material: CircularA FINMA document explaining how it will apply the law. It binds FINMA itself. FINMA says a circular needs no express statutory hook but must trace back to a higher rule. 2008/17 still describes the abolished direct-supervision regime in its annex — the library copy of that circular is flagged accordingly, and anything relying on it should be checked against the post-2020 statute.

Affiliation itself became a mini fit-and-proper test. Art. 14 para. 2 AMLA conditions SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. affiliation on internal rules and organisation guaranteeing AML compliance, on the good reputation of the firm and the persons responsible for its administration and management, and on qualified participants whose influence is not detrimental to prudent and sound business operations — the Art. 11 FinIA architecture, transposed to the unlicensed sector.

The enforcement edge is criminal. Carrying on a licensable activity — or an Art. 2 para. 3 AMLA activity without SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. affiliation — is an offence under Art. 44 FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG.: up to three years' custody if wilful, a fine of up to CHF 250,000 if negligent. The Federal Criminal Court's judgment SK.2021.17 of 2 December 2021 convicted on exactly that basis: financial intermediation carried on without the required SRO affiliation.

And the unresolved question the amendment answers. Crypto service providers sit today in the SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. channel: financial intermediaries under Art. 2 para. 3 AMLA, supervised for AML only, by private bodies. FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s Interpretive Note to Recommendation 15, para. 5, in the current consolidated text: "VASPs should be supervised or monitored by a competent authority (not a SRB), which should conduct risk-based supervision or monitoring." How Switzerland's rating survived that wording is the subject of Supervised by whom; what matters here is the population: FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s Annual Report 2024 counts 203 VASPs affiliated to SROs, of which 88 inactive, and the Federal CouncilThe seven-member Swiss executive. It makes ordinances and decides when laws come into force.'s own explanatory report puts it at around 200 as at mid-2024, of which around 115 active. The pending amendment would move that population — the active part of it — into FINMA prudential licensing without ever citing INR.15 §5 as the reason.

What the amendment would do to this architecture

The draft of 22 October 2025 is a revision of FinIA, and its structural moves are best read against the in-force Act (full analysis of the crypto substance in the companion dossier):

• Two new categories join Art. 2 para. 1 as letters f (payment institutions, draft Arts 51a ff.) and g (crypto institutions, draft Arts 51r ff.). That single amendment carries the whole general part with it: Arts 7–11 — organisation, place of management and the Art. 11 guarantee — would apply to both new categories as they do to the existing five.
• The authorisation chain is extended — asymmetrically. Under the draft's Art. 6, a banking licence and a securities-firm licence under Art. 41 let. a would each also carry authorisation as a crypto institution. Nothing cascades into the payment-institution licence — a bank wanting to issue a stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. would need the separate entity, which is the single most contested feature of the consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules..
• The new categories bypass the SO layer. The draft amends Art. 61 para. 3 so that payment institutions and crypto institutions are supervised by FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. directly, alongside managers of collective assets, fund management companies and securities firms. The two-layer architecture is not extended to the new categories; for the migrating VASPVirtual-asset service provider — an exchange, custodian or similar business handling crypto for customers. population the supervisor changes twice over — from SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. to FINMA, and from AML-only to prudential.
• Art. 1b of the Banking Act is repealed and its six licence-holders carried across under the transitional provision.
• The transition copies 2020, compressed. Draft Art. 74b mirrors in-force Art. 74: existing licence-holders comply rather than re-apply; newly caught firms apply within a deadline and may continue operating until FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. decides, provided they hold SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. affiliation. The difference is the deadline — twelve months to apply, against the three years the 2020 wave was given. The SROs, again, are the bridge; on the 2025 experience of 109 applications still pending years after a three-year window, the length of that bridge should not be assumed short.

The consultation's outcome — the record as at 29 August 2026

The consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules. closed on 6 February 2026. Since then, on the official record: nothing.

The only official forward-looking statement remains the SIF fact sheet of 22 October 2025 — a dispatch "at the earliest in the second half of 2026". That window is two months from closing, and the statement has been neither reaffirmed nor withdrawn. This practice re-checked SIF's media releases on 29 August 2026: the most recent items (19–21 August 2026) concern wage-data information exchange and a finance-ministers' meeting; nothing on FinIA, payment institutions, crypto institutions or stablecoinsA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC..

Two consequences follow. First, the in-force text stands unamended: the current consolidation of SR 954.1 on FedlexThe Swiss government's free official website for federal law. It shows each Act and ordinance as consolidated to a stated date. remains dated 1 March 2024, in German as in the English courtesy translation, verified 29 August 2026. Every claim in the first half of this dossier is a claim about law in force today. Second, any statement about what the consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules. changed in the draft is currently unknowable — the responses are analysed in the companion dossier, but the Federal CouncilThe seven-member Swiss executive. It makes ordinances and decides when laws come into force. has published no evaluation of them, and no revised text exists.

What this practice has not established

Stated plainly, because the gaps are part of the record:

• No consultation response from any Swiss SRO has been located — not VQF, not PolyReg, not the others most directly affected by losing their crypto membership. The likeliest explanation is filing without self-publication; the official FedlexThe Swiss government's free official website for federal law. It shows each Act and ordinance as consolidated to a stated date. submission register defeated automated retrieval when last attempted. No characterisation of the SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. position is offered anywhere in this dossier.
• The official respondent list and response count remain unread for the same retrieval reason.
• No official entry-into-force projection exists for the amendment, and none is invented here. The 1 January 2027 date still circulating in commentary predates the current silence and is not attainable on ordinary legislative mechanics.
• Per-SO membership figures are not published in the FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. materials reviewed, so the relative weight of the four supervisory organisations cannot be stated from the primary record.

For the practitioner

Check the right register for the right claim. A Swiss "asset manager" counterparty may be a FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.-licensed portfolio manager (FinIA register), an SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.-affiliated Art. 2 para. 3 intermediary (SRO member search), or neither. The licence claim and the affiliation claim verify in different places, and Art. 44 FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG. is what makes the difference criminal rather than administrative.

Ask which SO, and on what audit cycle. Ongoing supervision of a portfolio manager or trustee is performed by one of four private bodies, and the statutory audit cadence runs anywhere from annual to once in four years. Both facts are knowable and neither is cosmetic.

Treat fit-and-proper as an AML question. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s own 2025 licensing practice shows AML shortcomings surfacing as guarantee-of-irreproachable-business-conduct failures at the application gate. In diligence terms: the Gewähr record of the responsible persons is upstream of everything else, and it changes — at around 150 change requests a month across the sector.

Do not build plans on the amendment. No dispatch exists; the capital figures for both new licences are delegated to an ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. that does not exist; the transitional clock has no start date. What can be planned against today is the in-force Act — and the fact that, whenever the amendment lands, SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. affiliation is the condition for continuing to trade through the transition.

Key takeaways

• FinIA licenses five categories; FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. authorises all of them, but ongoing supervision of portfolio managers and trustees runs through four private supervisory organisations — a population that consolidated from five in the November 2025 OSFIN–FINcontrol merger.
• Fit-and-proper under Art. 11 operates on the institution, its managers and its owners; FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s 2025 practice reads it as fitness plus properness, and AML failures are being caught under it at the licensing gate.
• FinIA's Annex rewired the AMLA in 2020: portfolio managers and trustees became prudentially supervised intermediaries, and the SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. became the only channel for the parabankingThe Swiss term for financial businesses that are not banks — money changers, money transmitters, crypto firms, trustees. They are supervised by SROs, not by FINMA. sector — enforced by a criminal provision, as SK.2021.17 shows.
• The pending amendment would add payment institutions and crypto institutions to Art. 2, route both past the SO layer to direct FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. supervision, and move the roughly 200 SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.-affiliated VASPsVirtual-asset service provider — an exchange, custodian or similar business handling crypto for customers. (around 115 active, on the Federal CouncilThe seven-member Swiss executive. It makes ordinances and decides when laws come into force.'s figures) into prudential licensing.
• Since the consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules. closed on 6 February 2026 nothing official has been published — no results report, no dispatch, no parliamentary file — and the in-force text remains the 1 March 2024 consolidation.

Sources

Swiss law in force (consolidations as displayed on Fedlex, verified 29 August 2026)

• Financial Institutions Act (FinIA), SR 954.1 — consolidation of 1 March 2024; Arts 2, 3, 5, 6, 7, 11, 17, 20–24, 41, 61–62, 65, 74
• Financial Institutions Ordinance (FinIO), SR 954.11
• Financial Market Supervision Act (FINMASA), SR 956.1 — Title 3 (Arts 43a–43l), Art. 44 (held)
• Anti-Money Laundering Act (AMLA), SR 955.0 — Arts 2, 12, 14 (held)

FINMA (the register PDFs are live-generated and stamp their own date; copies of 29 August 2026 taken for this dossier)

• Supervisory organisations — list generated 29.08.2026: four SOs
• Self-regulatory organisations (SROs) — list generated 29.08.2026: eleven SROsA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.
• FINMA approves merger of two supervisory organisations, 11 December 2025
• Annual Report 2025 — pp. 16, 52–55, 63 (held)
• Annual Report 2024 — VASPVirtual-asset service provider — an exchange, custodian or similar business handling crypto for customers. affiliation chart, p. 64 (held)
• FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. list of Art. 1b BankA licensees — generated 29.08.2026: six institutions

The amendment (consultation package held in full, with this practice's English working translation; the German carries the citation)

• Federal Council, opening of the consultation, 22 October 2025
• Draft Act and explanatory report (Erläuternder Bericht, incl. impact assessment §5.4.2) — held
• SIF — DLT and blockchain dossier · SIF media releases — checked 29 August 2026

FATF and case law

• The FATF Recommendations, updated June 2026 — INR.15 §5 (held; read in the consolidated text)
• Bundesstrafgericht, SK.2021.17, judgment of 2 December 2021 (held)

Research and analysis, not legal advice · positions stated as at 29 August 2026 · the amendment is a consultation text and may change · English renderings of German sources are this practice's own working translation and are unofficial.