Regulatory Alerts2016-10-26
FINMA Circular 2011/1: Activity as a Financial Intermediary under the AML Act
The Swiss Financial Market Supervisory Authority (FINMA) issued this circular to clarify the scope of the Anti-Money Laundering Act (GwG) regarding persons acting as financial intermediaries. It defines covered activities such as credit business, payment services, trading, and asset management, while explicitly excluding non-financial activities like physical transport, collection, and accessory services. The document further details the criteria for professional activity, territorial applicability, and specific exclusions for intra-group transactions and certain leasing arrangements.
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