On 4 September 2017, the FINMA published for comments the draft revision of its AML-Ordinance. The revised Ordinance will address identified shortcomings highlighted in the FATF mutual evaluation report on Switzerland as well as incorporating findings gained by FINMA in the performance of its supervisory and enforcement duties.
The AFBS Roundtable should give the opportunity to discuss the amendments suggested by the FINMA.
Some of the proposed changes in the draft FINMA Ordinance Anti-Money Laundering refer to:
- Scope of application
- General and specific due diligence duties
- Management of legal and reputational risks: Analysis and reporting
- Verification of information on beneficial ownership
- Domiciliary companies
- Regular updating of client information
The AFBS Roundtable aims at discussing the proposed amendments and pinpoint to aspects which should be included in the in our comments to FINMA or propose them to be included into the SBA comments.
The amendment also affects the current CDB ’16. A working group is currently drafting the new CDB ’19. Further we want to inform on some changes in the CDB ‘16 (which will become the CDB ’19)
Christian Zuber will inform on discussions in the SBA working group on the revision of the CDB ’16. The revision is linked to the revision of the FINMA AMLO.