VQF SRO in Switzerland: membership & fees

The VQF (Financial Services Standards Association; Verein zur Qualitätssicherung von Finanzdienstleistungen, Zug) is an officially recognised Self-Regulatory Organisation (SRO) under Switzerland’s Anti-Money Laundering Act (AMLA). SROs issue binding AML rules for their members and monitor compliance through periodic audits and disciplinary powers. They are not prudential supervisors. In practice, professional financial intermediaries (PFI) that are not licensed by FINMA must satisfy AML duties by joining an SRO such as VQF and submitting to its rulebook and audits.

Members adopt the SRO’s AML regulations, implement internal controls (customer identification, beneficial owner verification, risk assessment, ongoing monitoring and suspicious activity reporting), maintain records, train staff and accept external AML audits under the SRO’s audit concept. FINMA recognises and oversees SROs, but the day-to-day monitoring of members sits with the SRO.

On 1 January 2020, the Financial Services Act (FinSA/FIDLEG) and the Financial Institutions Act (FinIA/FINIG) re-drew the boundary between AMLA/SRO oversight and prudential licensing:

• Independent portfolio managers and trustees now require a FINMA licence and are under ongoing prudential supervision by Supervisory Organisations (AO/SO) that are authorised and monitored by FINMA.
• The legacy status of directly subordinated financial intermediaries (DSFI/DUFI) under AMLA was abolished with effect from 31 December 2019; from 1 January 2020 these firms are no longer under direct AML supervision by FINMA.

Use the underlying activity—not your marketing label—to determine the route:

Common candidates include businesses that professionally accept, hold, arrange or transfer assets for third parties without engaging in licensed banking/securities/FinIA-licensable activities—for example, some payment facilitation or credit-broking models where client money handling triggers AMLA but not a prudential licence. Each design requires individual analysis; similar-sounding models can land on different sides of the line depending on custody, discretion and counterparty structure.

At a minimum, expect (i) board accountability for AML, (ii) a named AML/MLRO function, (iii) written policies covering KYC, beneficial ownership, PEP/sanctions, SoF/SoW, risk assessment, ongoing monitoring and reporting to MROS, (iv) record-keeping and training, and (v) periodic external AML audits under VQF’s audit/control concept.

Core admission pack items include the Application for SRO membership (VQF Doc-No. 901.1 for legal entities; 901.3for natural persons), the business/activity description (on VQF’s forms), personal declarations (VQF 906.1) and the consent to electronic dossier management (VQF 1200.1). VQF confirms that 901.1/901.3 and 1200.1 may be lodged electronically (no original by post) if signed appropriately.

VQF’s Fees Regulations (VQF Doc-No. 1101.5) set out admission, membership and audit charges. Note that the Express admission option was discontinued from 1 July 2019; all files are processed under the ordinary route.

VQF’s regulations provide the framework; audits are performed by accredited external auditors and supported by VQF’s audit/admin processes. VQF charges a flat CHF 500 admin fee and time-based rates for its own tasks; the external auditor bills separately.

Counterparties (banks, PSPs, partners) can verify SRO affiliation using FINMA’s SRO Member Search. Ensure your legal name and details are consistent across the SRO, the FINMA public tool and your own materials to avoid onboarding friction.

Expert tip (public footprint): many bank onboarding delays arise from discrepancies between the FINMA search entry, your SRO records and what your website claims. Align them first; it is a controllable risk.

Alongside its SRO role, VQF is also the Industry Organisation for independent Asset Managers (BOVV/IOAM) with FINMA-recognised rules of professional conduct (since 23 April 2009). Where relevant to your services, BOVV membership can be held in addition to SRO membership; fees are cumulative (BOVV flat rate CHF 500 p.a.). This does not replace a FinIA licence where one is required.

Sources: VQF admission guidance and form pages; newsletter confirming e-submission of 901.1/901.3 and 1200.1.

With a thorough market analysis in hand, it’s time to define your marketing strategy. This section outlines how your product or service will reach its intended audience and how you will generate visibility, leads, and ultimately revenue.

Every business needs a compelling sales pitch — a clear, concise articulation of what your company does, why it matters, and why people should care. This section ties closely with marketing but focuses more on direct customer engagement.

Assumptions: figures reflect published VQF fees plus indicative external audit hours for illustration; external auditors bill time-spent and will vary by risk/volume.