AML & Compliance

Service Overview

Regulatory compliance in the fintech and financial sectors is complex and rapidly evolving. Failure to maintain adequate Anti-Money Laundering (AML) and Know-Your-Customer (KYC) programs exposes companies to substantial financial penalties, reputational damage, and operational restrictions.

We provide comprehensive compliance guidance that balances regulatory requirements with business operational needs. Our approach combines legal expertise with practical implementation support to establish robust, sustainable compliance programs.

We specialize in:

AML/KYC program design and implementation
Regulatory compliance reviews and gap analysis
Internal control assessment and optimization
Staff training and compliance procedures
Suspicious Activity Reporting (SAR) guidance
Regulatory liaison and enforcement response

Compliance Services

AML Program Design & Implementation

We develop customized Anti-Money Laundering programs tailored to your business model and risk profile:

Customer Due Diligence (CDD) procedures
Enhanced Due Diligence (EDD) for high-risk customers
Customer Risk Assessment frameworks
Transaction monitoring thresholds and procedures
Customer screening and sanctions list compliance
Record retention and documentation standards

Regulatory Compliance Reviews

Comprehensive assessment of your organization's compliance posture:

Gap analysis against regulatory requirements
Policy and procedure documentation review
System and technology assessment
Staff training and awareness evaluation
Suspicious Activity Reporting (SAR) procedures
Risk assessment documentation

Internal Control Optimization

We assess and improve your internal control environment:

Organizational structure and reporting lines
Compliance officer authority and independence
Independent audit and testing procedures
System controls and automation
Segregation of duties implementation
Documentation and audit trail requirements

Staff Training & Awareness

Ensuring your organization understands and implements compliance requirements:

Comprehensive AML/KYC training programs
Role-specific compliance procedures
Red flags and suspicious activity recognition
Reporting obligations and procedures
Regulatory requirements overview
Annual refresher training coordination

Suspicious Activity Reporting (SAR)

We provide guidance on identification and reporting of suspicious transactions:

Red flags and suspicious pattern recognition
SAR filing procedures and requirements
Confidentiality and legal privilege protection
Documentation and record-keeping standards
Regulatory coordination and liaison
Follow-up and investigation support

Regulatory Response & Enforcement

If regulators initiate inquiries or enforcement action:

Regulatory inquiry response and coordination
Document production and disclosure management
Enforcement proceeding representation
Settlement negotiation and agreement
Remediation plan development and implementation
Ongoing compliance monitoring and reporting

Regulatory Framework

Swiss Regulatory Requirements

Compliance in Switzerland is governed by multiple regulatory frameworks depending on your business model:

FINMA (Financial Market Supervisory Authority)

Regulatory authority for banks and insurance
AML/KYC requirements for financial institutions
Financial platform directives and circulars
Enforcement authority for regulatory violations

SNB (Swiss National Bank)

Monetary policy and payment system oversight
Banking secrecy and privacy standards
International regulatory coordination
Financial sanctions and embargo enforcement

FOPH (Federal Office of Public Health)

Money Laundering Act (GwG) enforcement
Suspicious Activity Reporting requirements
Customer identification standards
Record retention and documentation

SECO (State Secretariat for Economic Affairs)

Export control and sanctions administration
Asset freeze and financial embargo enforcement
Terrorism financing sanctions
UN and EU sanctions implementation

International Standards & Requirements

FATF (Financial Action Task Force) recommendations
EU AML Directives (where applicable)
UN sanctions and terrorism financing provisions
OECD Tax Information Exchange standards
Basel Committee banking standards

Our Compliance Methodology

1. Assessment

Comprehensive review of current compliance posture and regulatory requirements.

2. Design

Development of customized compliance program tailored to your business model.

3. Implementation

Practical guidance on program rollout, staff training, and system deployment.

4. Monitoring

Ongoing compliance testing, updates, and optimization.

Risk-Based Approach

We employ a risk-based compliance methodology that tailors your program to your actual risk exposure. Rather than one-size-fits-all solutions, we develop proportionate controls that address your specific business risks while remaining operationally efficient.

Practical Implementation

We provide not just regulatory guidance, but practical support for implementation. This includes policy templates, staff training materials, system configuration guidance, and ongoing support to ensure your compliance program functions effectively.

Industries We Serve

Financial Platforms

Exchanges and trading platforms
Account providers and custodians
Online payment platforms
Financial service operations
Investment platforms

Financial Services

Alternative asset managers
Investment advisors
Payment processors
Remittance services
Crowdfunding platforms

Build Your Compliance Program

We help organizations establish robust, effective compliance programs that satisfy regulatory requirements while supporting your business objectives. Contact us for a confidential compliance assessment.

Zwirner Law

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