On December 5th, the Swiss regulator FINMA made minor changes to its AML circular regarding the obligations of financial intermediaries under its AML laws & regulations, known as AMLA. According to the notice, the most notable change was to the definition of which firms are defined to operate out of Switzerland:
In accordance with the definitive version of the circular, financial intermediaries are deemed to operate in or from Switzerland if they are domiciled in Switzerland, entered in the Commercial Register or have a de facto branch office in Switzerland. Such branch offices also cover persons who permanently assist foreign financial intermediaries in carrying out key aspects of their financial intermediation activities in or from Switzerland. This can include receiving or handing over assets or providing financial intermediary services. This rule is in line with FINMA’s practice.