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Swiss SRO Membership

Learn what is a Swiss SRO membership, how to join a Swiss SRO, the application process, the key requirements, and the benefits for fintech, crypto, and financial firms seeking AML compliance in Switzerland.

What Is an SRO Membership? 

Requirements & Benefits

An SRO membership is an affiliation with a Self-Regulatory Organization (SRO) recognized by the Swiss Financial Market Supervisory Authority (FINMA). This affiliation, often called AML registration — or colloquially referred to as a Swiss crypto license, SRO license, Swiss PSP, or financial intermediary license — enables you to conduct financial activities that do not require direct FINMA licensing. It is particularly attractive due to its straightforward process and swift approval.

Switzerland currently counts 11 SROs (see complete list of Swiss SROs), including VQF and SO-FIT. This is why some refer to a VQF license, SO-FIT license, or SRO licence. In reality, these terms simply denote affiliation with an SRO. Professional financial intermediaries pursuant to Art. 2 para. 3 of the Anti-Money Laundering Act (AMLA) must join an SRO recognized by FINMA in accordance with Art. 14 para. 1 AMLA.

SROs have the authority to establish their own regulations, guidelines, and AML processes within the legal framework set by Swiss law and FINMA. Some SROs simply reference FINMA's AML regulations in their internal guidelines, while others opt to draft their own, often mirroring or closely aligning with the FINMA AML Ordinance. Members of an SRO are required to comply with these regulations and undergo regular AML audits to ensure continued adherence.

Companies that are SRO members can be found on the FINMA website: Search for an SRO member

 

What Are the Key Benefits of the SRO Licence?

A Swiss SRO licence, i.e. a SRO membership, offers several advantages, including a more flexible regulatory environment compared to obtaining a direct FINMA license. The application process is typically straightforward and efficient, with approval generally being swift. In addition, the SRO license boosts credibility and fosters trust among clients by ensuring full compliance with Swiss regulatory standards.

Finally, an SRO membership allows for the combination of crypto and payment activities under the same entity. This is one of the advantages, as it effectively combines the roles of a PSP (Payment Service Provider) and a VASP (Virtual Asset Service Provider) within the same company.

More information can be found in our presentation below:

What Are the Financial Services Authorized With an SRO Membership?

An SRO membership grants access to the financial intermediary activities in Switzerland and enables you to conduct businesses such as:
• Currency & crypto exchanges (on/off ramp)
• Payment processing
• Remittance
• Crypto custody with individual wallets
• Crypto wealth management
• Crypto brokerage
• Issuing cryptocurrencies (ICO, TGE)
• Acceptation of clients' funds (sandbox & exemptions)
• Precious metals dealing and commodities trading
• Lending operations

More information can be found in our presentation below.

Overview Of The SRO Membership Application Process

The SRO affiliation process consists of three main steps:

Step 1 Preparation: Once the company is incorporated in Switzerland, we draft the business plan and define the scope of services to be offered. We also assess whether a FINMA license is required.

Step 2 Application: We complete all SRO application forms and gather the necessary personal documents for the directors and AML Officer, and draft the AML & CTF policy and processes. A check list of the documents required for the SRO membership application can be found here (VQF example).

Step 3 Submission & Review: Once everything is in order, we submit the application to the SRO. The SRO will then conduct a detailed review and may request additional information or clarifications.

Step-by-step overview of the SRO membership licensing process

Top Most Frequently Asked Questions About SRO Membership

At least one local director with individual signing authority is required.

Yes, having an AML Officer is mandatory. This role, i.e. the second line of defense, can be outsourced to individuals meeting the required fitness and properness criteria, which is a common option for new companies.

It depends on your business. For companies focused on payments or crypto, we typically work with VQF or SO-FIT. We will guide you through the selection process.

There is no regulatory capital requirement for SRO membership, meaning no buffer must be maintained as with banks. However, establishing a company in Switzerland requires a capital contribution. A Ltd company (AG, SA) requires CHF 100,000 in capital, with at least CHF 50,000 paid up at incorporation. For an LLC (GmbH, SARL), the capital is CHF 20,000, and it must be fully paid. This capital can generally be used by the company for its activities, though certain corporate law requirements (Art. 725 CO) regarding governance must be followed, especially in cases of capital loss or over-indebtedness.

The affiliation process, once the application is submitted to the SRO, generally takes between 1 to 3 months, depending on the case. The SRO will specifically assess the anti-money laundering framework and ensure the fitness and properness of the AML officer (who can be outsourced) as well as the external AML auditor. SynHedge will connect you with all the necessary parties. The SRO license is particularly valued for its swift approval process. 

Yes, an SRO membership allows for the combination of crypto and payment activities under the same entity. This is one of the advantages, as it effectively combines the roles of a PSP (Payment Service Provider) and a VASP (Virtual Asset Service Provider) within the same company.

Yes, an SRO member can apply for a FINMA license. Once obtained, the SRO membership becomes unnecessary, as all financial activities of the company, including AML compliance, fall under FINMA’s direct supervision. Effectively, the FINMA license replaces the SRO membership.

Do not hesitate to reach out. We’ll be happy to answer your questions and assess how we can best support you. Book a call now or email us at info@synhedge.com

SynHedge As Your Swiss Legal & Regulatory Partner

SynHedge supports you throughout the entire authorization process and beyond. We guide you through each step, ensuring compliance and efficiency. Additionally, SynHedge connects you with all the necessary parties to help you operate seamlessly.

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