Almost every week, someone tells me: “I have an SRO, so I am regulated in Switzerland.” Sometimes that is true. Often it is only half true. And sometimes it is the beginning of a serious problem.
Two very different things
An SRO (self-regulatory organisation) supervises compliance with the Anti-Money Laundering Act. It checks that you know your clients, verify where their money comes from, keep records and report suspicious transactions. The SROs are recognised and supervised by FINMA. But an SRO does not authorise your business. It supervises your anti-money-laundering duties.
A FINMA licence authorises a regulated activity: managing clients’ assets, acting as trustee, running funds, trading securities for clients, or accepting deposits. It comes with requirements on organisation, people, capital and ongoing supervision.
In short: the SRO asks “do you know who your client is?” The licence asks “are you allowed to do this at all?”
Who needs only an SRO
The Anti-Money Laundering Act covers “financial intermediaries”, meaning businesses that handle or help move other people’s money without needing a FINMA licence for it. Typical examples:
- payment services and money transfer;
- currency exchange;
- lending, such as consumer loans, mortgages, factoring or leasing;
- trading in foreign exchange, precious metals (including gold), commodities or securities, for clients;
- certain crypto services, such as transfers or custody of crypto assets for clients.
Since 2023, these businesses can no longer be supervised directly by FINMA for anti-money laundering. They must join an SRO.
Who needs a licence
If you do any of the following, an SRO is not enough:
- you manage assets for clients: portfolio manager licence;
- you act as trustee: trustee licence;
- you manage collective assets or run funds;
- you trade securities for clients in a way that makes you a securities firm;
- you accept deposits from the public on a commercial basis: a fintech licence or a banking licence, depending on what you do with the money.
The mistake I see most often
The founder defines his business as narrowly as possible to stay at SRO level, then grows into a licensed activity without noticing.
He starts with payments, then holds client money a little longer, then pays a little interest to keep clients happy. At that point he may be accepting public deposits, and that is a banking question, not an SRO question.
Or he executes clients’ crypto transfers, then starts “optimising” their positions for them. At that point he may be managing assets.
Nobody sends you a letter when you cross the line. You find out when your bank asks, when an auditor asks, or when FINMA asks. By then, the question is no longer which licence you need. It is what you have been doing without one.
What an SRO does not give you
An SRO membership is valuable, and for many businesses it is exactly the right level. But be clear about its limits:
- it does not allow you to do anything that requires a licence;
- banks and partners know the difference, and many will ask what your SRO membership actually covers;
- it does not make you a “Swiss regulated financial institution” in the sense most clients understand.
What is coming
For crypto businesses, the line between “SRO only” and “licence” is about to move. The Federal Council has proposed a new crypto-institution licence for crypto service providers, and a payment instrument institution licence to replace the fintech licence. Many businesses that live today with an SRO membership alone will then have to look at a licence. If you are setting up a crypto business now, build it so that it can be licensed later.
Three questions before you choose
- What exactly will you do with clients’ money? Hold it, move it, invest it, lend it?
- What will your business look like in two years, not only on the day you start?
- Whose money is it, and who decides what happens to it?
Answer those honestly and the choice between an SRO and a licence usually becomes obvious. If it does not, that is precisely the moment to take advice. Restructuring later costs much more.
Read next: Swiss SRO Licence 2026: Requirements, Cost, Timeline and, for crypto businesses, Swiss Crypto Licence 2026.
Not sure which side of the line your business sits on? Contact FintechLex · insight@fintechlex.com
Last updated: October 2026. This article is general information, not legal advice. Sources: Anti-Money Laundering Act (AMLA); Financial Institutions Act (FinIA); FINMA, information on self-regulatory organisations and licences; Federal Council, press release of 22 October 2025 on stablecoins and crypto-institutions.
