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Switzerland jurisdictional requirements
Switzerland jurisdictional requirements
C
Written by Catarina Veloso
Updated over 4 months ago

In Switzerland, Travel Rule requirements are set forth in the AMLO-FINMA, and the FINMA Guidance 02/2019, amended in 2020, as well as the Regulations of the VQF Financial Services Standards Association pursuant to the Anti-Money Laundering Act.pdf ("Regulations")

Threshold

Although the New Financial Services Act FinSA and Financial Institutions Act FinIA (in effect since 1 January 2020) sets a compliance threshold of 1,000 CHF, the interpretation of local authorities is that the application of Article 14 of the VQF Regulations implies a requirement to transmit Travel Rule information for most transactions, regardless of transaction amount. According to this provision, the exemption to not send Travel Rule information below 1,000 CHF would only apply under certain circumstances - in particular, it only applies in cases where the VASP is able to verify that the transaction is with its own customer or where the VASP verifies the identity of the third party involved in the transaction by carrying identity checks and verifying their control over the wallet. For this reason, in practice, most transactions are treated as requiring Travel Rule information transmission regardless of its amount. Therefore, for simplicity, the system enforces a threshold of 0 CHF and treats all transactions as being subject to Travel Rule requirements.

Resources on this subject: Section "The Compliance Run: Alpine Hurdles" in https://www.mme.ch/en/magazine/articles/travel-rule-spotlight-switzerlands-ambitious-approach

Required Originator and Beneficiary information vs Notabene system

Party to the TX

Required information (*)

IVMS field

Required?

Originator

Name

name

Yes

Originator

Account number

accountNumber

Yes

Originator

Address

geographicAddress

OR

Originator

National identity number

nationalIdentification

OR

Originator

Customer number

customerIdentification

OR

Originator

Date and place of birth

dateAndPlaceOfBirth

OR

Beneficiary

Name

name

Yes

Beneficiary

Virtual asset account number

accountNumber

Yes

(*) According to Article 10 of the AMLO-FINMA.

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