Swiss SRO Membership (Swiss VASP License)

Understand what an SRO membership entails in Switzerland, who needs it, and why it’s especially relevant for fintech, crypto, and financial service providers seeking (AML) compliance.

Navigating Compliance Entry Points: Accessing the Swiss Financial Market

What Is an SRO Membership?

In Switzerland, an SRO (Self-Regulatory Organisation) membership refers to the affiliation with a private organisation recognised by the Swiss Financial Market Supervisory Authority (FINMA) under the Anti-Money Laundering Act (AMLA). While often referred to as a "Swiss crypto licence", "Swiss VASP License", "SRO licence", or "VQF membership", this affiliation is not a financial licence in the traditional sense. Instead, it grants access to the Swiss market for certain financial services that do not require direct FINMA authorisation.

Switzerland currently has 11 FINMA-recognised SROs, such as VQF, PolyReg and SO-FIT. Joining one of these is mandatory for professional financial intermediaries according to Art. 2 para. 3 and Art. 14 para. 1 AMLA if they are not directly supervised by FINMA.

Key Requirements & Advantages

Each SRO operates within the legal framework defined by Swiss law but sets its own compliance guidelines — especially regarding anti-money laundering (AMLA). Some SROs adopt FINMA’s AML Ordinance directly, while others issue their own rules that often closely mirror it. Member firms are required to comply with these regulations and are subject to regular AML audits.

Benefits of joining an SRO include:

Enables access to the Swiss financial market for certain regulated activities without requiring full FINMA licensing
Comparatively fast, straightforward membership process
Clear compliance expectations for fintech startups and established firms alike
Attractive regulatory framework for crypto service providers

Companies acting as financial intermediaries – such as those facilitating transactions or offering crypto custody – typically require at least an SRO affiliation, unless these activities are fully covered by a FINMA licence (e.g. banking license). This setup makes the SRO model particularly suitable for agile financial service models that want to operate under Swiss law with a clear compliance path.

If you're looking to apply for SRO membership in Switzerland, especially as a VASP or financial intermediary, you'll need to submit a well-prepared application that includes specific documents and internal policies. Many applicants underestimate the complexity and submit incomplete or poorly structured materials – which can delay or even jeopardize approval.Key requirements include (non-exhaustive):

Completed Application Form with full company and contact details
Business Activity Description clearly outlining services offered (e.g. VASP, payment facilitator)
Articles of Association and recent commercial register extract
AML Policy tailored to your risk profile – for VASPs, this must cover Travel Rule obligations
Organizational AML Framework: Roles of AML Officer and Deputy, plus outsourcing agreements if applicable
Ownership & Group Structure including direct and indirect shareholders up to the beneficial owners
Financials & Forecasts: recent balance sheet, profit & loss, and cash flow chart (optional but useful)
Personal Documents for board members and qualified shareholders: CV, ID, criminal record, declarations
Other SRO Forms: e.g. Power of Attorney, Internal Guidelines, Mandate Confirmation of Auditor

Yes. You must appoint a qualified AML Officer and, depending on your setup, a Deputy or an authorized person with access rights, who is resident in Switzerland. This is a non-negotiable requirement of all recognized Swiss SROs.

This function can be outsourced, provided the regulatory prerequisites are met. We offer compliance outsourcing as a recognized external AML Officer for Swiss SRO members.

Typical issues include:

AML policies that don’t meet Swiss standards – e.g., AI-generated templates (ChatGPT), reused foreign documents, or vague risk frameworks
Missing internal roles, such as the mandatory AML Officer and Deputy
Incomplete or incorrectly filled SRO forms, leading to delays or rejections
Vague or inconsistent business descriptions, especially for crypto or fintech services
Lack of a Swiss-based AML Officer, which is a mandatory requirement

These issues can cause significant delays or even rejection of your SRO application. At Gecko Compliance AG, we know what the SROs are looking for — and more importantly, what they will reject. Let us help you get it right from the start.

Don’t Risk Rejection – Let Us Guide You

Whether you’re just starting out or stuck somewhere in the process—we know how Swiss compliance really works. From strategy to submission to full operations, we support you every step of the way.

We help you avoid common pitfalls by preparing your documentation in line with the SRO’s expectations and current AML standards. Whether you’re building an AML policy from scratch or adapting an existing one, our experts support you in creating a compliance setup that is solid, practical, and ready for regulatory review.