Swiss SRO membership — benefits & requirements

What it is, and why it matters

In Switzerland, anti-money-laundering supervision for financial intermediaries runs through FINMA (the Swiss Financial Market Supervisory Authority) down to a Self-Regulatory Organisation (SRO), and from there to your SRO-member AG or GmbH. It is a stable regime that has operated under the Anti-Money Laundering Act (AMLA) for more than 25 years.

Three SROs matter in practice: VQF (the largest, English-speaking), SO-FIT (Geneva, French-speaking) and PolyReg (German-speaking).

Key benefits

• PSP, VASP and card programmes under one licence
• A stable, trusted Swiss regulatory framework
• SRO credentials widely accepted by EU acquirers and fintech partners
• Free from EU bureaucracy (MiCA hurdles) for EU clients onboarded on a non-solicitation basis
• USDT accepted without restrictions
• Moderate capital — CHF 20k (GmbH) or CHF 100k (AG)
• ~4 months to a membership decision
• Low corporate tax (e.g. Zug at ~11.85%)

Client funds — the two-bucket reality

Under the SRO regime, client funds fall into two categories. Only one is capped.

Not counted as deposits — unlimited (the mainstream case for SRO members):

• Funds received for immediate exchange (fiat or crypto)
• Settlement accounts — funds settled within 60 days (payment processing)
• Funds from corporate clients with a professional treasury (Art. 5 para. 3 lit. c BO)
• Funds covered by a Swiss bank default guarantee (Art. 5 para. 3 lit. f BO)
• Crypto held in segregated custody wallets

Deposits — CHF 1m cap (sandbox): no interest paid, no investment of client funds, and transparent disclosure of the absence of FINMA supervision and deposit insurance. Need to scale? A FinTech licence (Art. 1b BankA) raises this to CHF 100m; a full FINMA banking licence removes the cap entirely.

Application process & timeline

Phase 1 — Incorporation & preparation (~8 weeks, run in parallel where possible)

• Company formation (AG or GmbH) — name, capital, notary, Commercial Register
• Office and domiciliation; local board-member onboarding
• Short business plan and organisational chart
• External AML officer (MLRO) and AML auditor selection
• AML policy drafting (plus an AML workshop)
• Personal documents and KYC collection; completing the SRO application forms

Phase 2 — SRO review (4–12 weeks, depending on the SRO pipeline)

• Application review by the SRO
• Q&A with the SRO; a legal opinion if requested
• SRO decision → membership granted
• AML framework go-live with MLRO and KYC tooling

End-to-end, from kick-off to SRO membership: ~4 months in a typical case.

Substance requirements

Mandatory from day one:

• A Swiss company — AG or GmbH
• A physical office (no virtual / c/o address)
• One Swiss-resident board member with sole signing authority
• A local AML officer (MLRO) — can be outsourced
• A local external AML auditor
• A Swiss accountant

Build-up within 6–12 months: employee(s) in Switzerland (part-time possible), and optionally Swiss-resident shareholder(s), IT infrastructure in Switzerland, a Swiss bank or fintech account, and a local Head of Business Development on the board.

Dormant and shell companies are no longer accepted. SROs check substance at admission and during ongoing supervision.

Economics — setup & ongoing costs

One-time — contact us:

Running — ~CHF 36k / year (≈ CHF 3k / month baseline, excluding staff hires):

Plus 1–2 Swiss staff hires within year one (~CHF 3–4k / month each). IT and an optional legal opinion (~CHF 2.5k) are scoped case-by-case.