AML training for SRO members: requirements and implementation
SRO members must ensure adequate training of their staff (Art. 8 AMLA, for advisors Art. 8d AMLA). Who is trained, how often and in which format is set out in the regulations of their SRO; the SRO checks compliance. Whether external or in-house training is recognised is also decided by the SRO.
Who is affiliated with an SRO
Financial intermediaries under Art. 2 para. 3 AMLA – for example in lending, payment services or as investment advisors – and, since 1 October 2026, advisors under Art. 2 paras. 3bis and 3ter AMLA must join a self-regulatory organisation (Art. 14 AMLA). FINMA keeps the list of recognised SROs.
What the regulations specify – two examples
| PolyReg (regulations, in force since 1.3.2025) | VQF (training concept, version of 21.9.2023) | |
|---|---|---|
| Who | Operational governing bodies and all employees with AML-relevant tasks (§60 para. 2) | All governing bodies and employees in the AML area, as well as the AML officer and deputy (Art. 5) |
| Basic training | Within six months of joining (§61 para. 2) | Within twelve months of joining or of starting the activity (Art. 6 para. 1) |
| Further training | Annually (§60 paras. 1 and 3) | In the cycle set by the board (Art. 6 para. 2); according to VQF every two years |
| In-house training | Own basic training with authorisation and an approved training concept (§61 para. 3); additionally, in-house training on the member’s own directives (§60 para. 2) | Possible for employees if equivalent; the AML officer and deputy are in principle trained externally (Art. 9) |
| External providers | Further training recognised upon prior request (§61 para. 1) | Recognition upon request if equivalent; prior review recommended (Art. 8) |
The other SROs – for example ARIF, SO-FIT, SRO-TREUHAND|SUISSE or SRO SAV/SNV – set out training requirements in their own regulations. FINMA keeps the complete list of recognised SROs.
Implementation in five steps
- Read the regulations: check your SRO’s training provisions for deadlines, cycle and recognised formats.
- Identify who must be trained: governing bodies, the AML officer and all employees with AML-relevant tasks.
- Clarify recognition: if external or in-house training is to count, clarify recognition with the SRO in advance – PolyReg requires a prior request, VQF recommends a prior review.
- Train on your own directives: in addition to basic and further training, explain your internal measures (expressly required by PolyReg, §60 para. 2).
- Keep records: document attendance, content and materials so that the SRO audit can follow them.
- Current version of your SRO’s regulations at hand – training provisions read.
- List of everyone who must be trained, with their start date.
- Deadlines for new employees in the calendar.
- Recognition of external or in-house training clarified with the SRO.
- Complete records for the next SRO audit.
Sources
- Anti-Money Laundering Act (AMLA), SR 955.0 – English translation (not legally binding)
- FINMA: self-regulatory organisations (SROs)
- SRO PolyReg regulations under Art. 25 AMLA, in force since 1 March 2025, §60–63 (German)
- VQF training concept (doc. 610.1), version of 21 September 2023 (German)
- VQF: rights and obligations of members (German)
This article provides an overview and does not constitute legal advice. The cited legislation and your SRO’s regulations are authoritative; legal provisions are paraphrased in English.
The FinReg Swiss AML training records every completion automatically – with date, content, version and test result for each person.