Swiss SRO Membership

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 licence). 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, 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.