Checklist for financial intermediaries

General remarks

The anti-money laundering system currently used in Switzerland draws a distinction between suspicious activity reports (SARs) on the basis of intensity of suspicion of money laundering. These suspicions fall into one of two categories: cases where there are reasonable grounds for suspicion, or cases where there is merely suspicion. Each of these two categories is dealt with by two separate pieces of legislation (Article 9 Anti-Money Laundering Act AMLA or Article 305ter paragraph 2 Swiss Criminal Code SCC), which in turn have different consequences for the financial intermediaries and the authorities.

When confronted with a business relationship where elements justify the submission of a SAR to MROS, the financial intermediary must first determine whether the case falls within the scope of application of Article 9 AMLA or Article 305ter paragraph 2 SCC. However, the financial intermediary is not free to choose between the application of these two provisions: in the first case he has a duty to report, whereas in the second case he has a right to report.



A general checklist can be printed and (together with the respective annexes) sent by FAX - or in absence of a FAX - by priority mail to MROS.

Due to security reasons MROS cannot receive any reports by e-mail.




to the top Last modification 29.01.2016


Federal Office of Police
Money Laundering Reporting Office Switzerland (MROS)
Nussbaumstrasse 29
CH-3003 Bern
+41 58 463 40 40
+41 58 463 39 39