Recognizing that most fintech license applicants are likely to be smaller institutions, the Swiss regulator, FINMA, is proposing to introduce some organizational relaxations for them. Specifically, an exemption from the requirement to establish an independent anti-money laundering unit with monitoring duties. Small institutions are defined as those with gross revenues of less than CHF1.5 million ($1.5mn).
In mid-June 2018, the Swiss parliament launched a new licensing category, known as the “FinTech licence”, which will apply to institutions that accept public deposits of up to CHF100 million, but which do not invest or pay interest on them. These institutions will be subject to the Anti-Money Laundering Act (AMLA) and its due diligence requirements. As a result, it has become necessary to revise the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA).
The corresponding due diligence requirements under AMLA must now be defined in detail for institutions that will fall within this new category. This will necessitate changes to some of the provisions of AMLO-FINMA, and the Swiss Financial Market Supervisory Authority FINMA has opened a consultation on this topic.