The case
FINMA recently published its Annual Report for 2022.
Quote: “Combatting money laundering is one of FINMA’s core tasks. As part of its money laundering supervision activity in the year under review, it has also been conducting checks on the preventive measures implemented by banks and has issued clarifications regarding their respective requirements.”
Source: FINMA
The commentary
It makes sense for financial intermediaries (trustees etc.) to understand what FINMA focuses on and adjust their control framework wherever necessary. Some takeaways regarding FINMA’s statements on money laundering supervision:
- It is essential to clarify the background of complex client structures in detail and make sure the documentation is coherent.
- Adhere to the defined target markets as business activities which fall outside of the target markets can entail a higher risk due to them not being covered by the firm’s current risk management policy.
- The periodic AML risk analysis conducted by financial intermediaries needs to entail specific measures for mitigating the identified risks.
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