This is one of the most important points for the regulatory body while assessing the application.
In addition to the complex national legislation and regulations, the Swiss Confederation has signed and agreed to the number of international treaties related to the anti-money laundering and terrorism prevention sphere. GwG
(Geldwaschreigesetz, German. "Anti-Money-Laundering Act") applies to financial intermediaries and governs the combating of money laundering and terrorist financing. It ensures the exercise of due diligence in the conduct of financial transactions.
FINMA elaborates norms for control over the client's transactions, on-boarding procedures, frequency of the audits for the financial intermediaries and clients, process of notification about the suspected transactions. MROS
(Meldestelle für Geldwäscherei) receives information about the suspected activities of the clients (natural persons and legal entities), financial intermediaries, and acts in order to stop such transaction, for example by blocking the funds. In addition, it forwards the information to the international bodies related to anti-money laundering (FATF checks the fulfilment of FATCA etc.).
In order to comply with all requirements and fulfil legal obligations, the financial intermediary shall have the independent employee, that will control the AML procedures and their effectiveness in the company. In the small or mild companies, the same person is usually responsible for the on-boarding of the new clients, risk management and compliance rules.
The AML officer can be either employee of the company or the separate independent company, that provides External AML Officer according to the contract.
The documents and information list for the AML officer during the financial license application is usually the same as for the director of the company.