Group companies under the Anti Money Laundering Act

Banking and securities trading groups can obtain authorisation from FINMA allowing them to supervise directly subordinated financial intermediaries that form part of their group.

Any individual or company acting professionally as a financial intermediary must either join a self-regulatory organisation (SRO) or obtain a licence from FINMA as a directly subordinated financial intermediary (DSFI). Once FINMA grants the licence, the DSFI’s compliance with due diligence requirements for combating money laundering is monitored.

If a DSFI forms part of a banking or securities trading group, it may be included in FINMA’s consolidated supervision on request if the group monitors the DSFI’s compliance with the relevant money laundering provisions.

Requirements for including a DSFI in consolidated supervision

FINMA only grants the request to include a DSFI in its consolidated supervision of a financial group if the DSFI:

  • is involved in financial business with relevance for money laundering;

  • is entered in the Commercial Register as a commercial company or operates with an official licence;

  • ensures compliance with its obligations under the Anti-Money Laundering Act (AMLA) through its internal regulations and organisation;

  • together with those responsible for its strategic and executive management, has a good reputation and guarantees compliance with its obligations under AMLA;

  • acknowledges that FINMA can impose measures on it under Article 29ff. FINMASA and Article 20 AMLA.

Duration of the licensing process

The licensing process for including a group DSFI in consolidated supervision normally takes about three months.

Contact for queries

The Authorisation section of the Banks division (