Financial Crime Compliance services in Switzerland and Liechtenstein

Financial crime compliance is the set of controls a financial institution runs to prevent, detect and report money laundering, terrorist financing, sanctions breaches, bribery and corruption. In Switzerland the core obligations come from the Anti-Money Laundering Act (AMLA), FINMA's Anti-Money Laundering Ordinance and the sanctions ordinances administered by SECO. In Liechtenstein, the Due Diligence Act supervised by the FMA plays the same role. In practice it covers customer identification (KYC), due diligence, transaction monitoring, sanctions screening and the reporting of suspicious activity to MROS.

A framework typically has five parts: a documented money laundering and sanctions risk assessment; policies and procedures covering onboarding, due diligence, monitoring and reporting; a governance structure with clear roles for the board, senior management and the compliance function; systems for screening and transaction monitoring; and training, testing and management reporting that show the controls work. The framework should be proportionate to the institution's size, business model and risk exposure.

Most operational activities can be outsourced or co-sourced: KYC onboarding and periodic reviews, customer and enhanced due diligence, sanctions and adverse media screening, transaction monitoring alert reviews, KYC remediation and backlog reduction, quality assurance and control testing. Responsibility for the compliance framework, risk decisions and reporting to the regulator stays with the institution. In Switzerland, outsourcing of significant functions falls under FINMA's outsourcing rules, which set requirements on oversight, documentation and access to data.

KYC managed services are an arrangement where an external provider runs part or all of an institution's KYC operations on an ongoing basis: onboarding files, periodic reviews, refresh campaigns, enhanced due diligence reviews and backlog remediation. The provider supplies the team, the quality controls and reporting against agreed service levels, while the institution keeps ownership of its policies, risk appetite and final decisions. Teams can be onshore, offshore or a mix of both.

Any financial intermediary subject to the Anti-Money Laundering Act: banks, insurers, asset managers, securities firms, payment service providers, fund managers, fiduciaries and crypto service providers. Requirements are proportionate to the risk each business carries. Non-financial companies are also exposed, in particular through sanctions and export controls and through anti-bribery and anti-corruption obligations, and may need similar support.

Our financial crime compliance specialists bring a unique combination of regulatory, risk management, and operational expertise. We do not simply advise on regulatory requirements; we help institutions implement practical KYC, AML, and sanctions frameworks that stand up to regulatory scrutiny, support business growth, and deliver measurable operational effectiveness.