Process
Our approach to AML policy development
We follow a structured process to ensure your AML policy is comprehensive, effective, and fully compliant with regulatory obligations in Switzerland.
01
Policy assessment & gap analysis
Review of existing AML policies and procedures
Identification of gaps based on Swiss AML regulations (AMLA, AMLO-FINMA, SRO regulations)
Benchmarking against best practices in the industry
02
Customization & policy drafting
Tailored AML & CTF policies adapted to your business model and risk exposure
Integration of regulatory requirements, including transaction monitoring, enhanced due diligence, and PEP screening
Incorporation of Travel Rule compliance and verification procedures for crypto transactions
Development of risk-based approaches specific to VASPs and financial intermediaries
03
Implementation & compliance framework set-up
Development of operational procedures for your first line of defence (e.g., customer onboarding, transaction monitoring)
Flowcharts and process documentation for compliance teams and developers
Integration of automation tools and RegTech solutions for compliance efficiency
04
Ongoing review & compliance monitoring
Regular updates to reflect changes in AML laws and regulations
AML training for employees to ensure proper policy implementation
Ongoing updates if outsourcing is handled by us, ensuring that policies—especially risk classifications such as FATF country lists—remain fully aligned with the latest regulatory standards
FAQ
Frequently asked questions on AML policies
Why is having a strong AML policy essential for financial intermediaries and VASPs?
An AML policy is a mandatory requirement for financial intermediaries and Virtual Asset Service Providers (VASPs) operating in Switzerland. It outlines the necessary procedures for detecting, preventing, and reporting money laundering and terrorist financing activities. A well-structured AML policy ensures regulatory compliance and protects businesses from financial and reputational risks.
How often should an AML policy be reviewed and updated?
AML policies should be reviewed at least annually and updated whenever there are significant regulatory changes or operational shifts. For example, when the FATF updates its country classifications, businesses must adjust their risk-based approach accordingly.
At Gecko Compliance AG, we proactively inform our clients about relevant regulatory updates and ensure their AML policies remain aligned with the latest standards. For clients outsourcing compliance to us, we guarantee ongoing updates—not just at issuance—keeping key elements such as risk classifications, country lists, and transaction monitoring frameworks fully up to date.
What are the key components of an effective AML policy?
A comprehensive AML policy should include:
Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
Transaction monitoring and risk-based screening
Enhanced due diligence (EDD) measures for high-risk customers
Suspicious activity reporting (SAR) and escalation processes
Compliance with the Travel Rule for crypto transactions (where applicable)
FATF country risk classification and sanctions screening
AML training and awareness programmes for employees
Record-keeping and audit readiness
How does the Travel Rule impact AML policies for crypto businesses?
The Travel Rule mandates that financial intermediaries and VASPs must share identifying information about both senders and recipients of crypto transactions. The FATF allows countries a de minimis threshold of USD/EUR 1,000. Switzerland applies the rule without a threshold: FINMA treats crypto transfers like payment orders under Art. 10 AMLO-FINMA (FINMA Guidance 02/2019).
Your AML policy should outline:
Procedures for collecting and verifying customer information
How your business ensures compliance when dealing with other VASPs or financial institutions
Technical and procedural solutions for secure data transmission
What role does risk-based assessment play in an AML policy?
A risk-based approach (RBA) is crucial in AML policies, as it allows financial institutions and VASPs to focus resources on higher-risk customers and transactions. An effective AML policy includes:
A risk classification framework based on customer profiles, business activity, and geography
Ongoing transaction monitoring to detect unusual patterns
Triggers for enhanced due diligence (EDD) when dealing with high-risk individuals or jurisdictions
Can AML policies be automated for better efficiency?
Yes, integrating RegTech solutions with your AML policy significantly improves efficiency by automating:
KYC and onboarding procedures
Transaction monitoring and risk scoring
Real-time screening for sanctions, PEPs, and adverse media
Regulatory reporting and suspicious activity alerts
At Gecko Compliance AG, we help financial intermediaries and VASPs integrate AML compliance tools that streamline processes and ensure seamless regulatory adherence.
What happens if an AML policy is outdated or non-compliant?
Failure to maintain an up-to-date AML policy can result in:
Regulatory fines and enforcement actions
Loss of banking relationships or licensing issues
Reputational damage and operational risks
To avoid such consequences, businesses must regularly update their AML policies and ensure alignment with Swiss AMLA, FINMA, and international FATF standards.
How can Gecko Compliance AG support AML policy creation and updates?
We offer tailored AML policy solutions that include:
Drafting and customizing AML policies to fit your business model
Integrating regulatory requirements, including Travel Rule compliance
Providing operational handbooks and workflow documentation for first-line staff and developers
Continuous monitoring and updates for outsourced compliance clients
Our support
Take control of your AML compliance
A strong AML policy is essential for regulatory compliance and risk mitigation. Whether you need a new policy, an update, or full compliance outsourcing, we are here to support you.
Contact us today to ensure your AML policy meets all Swiss and international requirements.