In Switzerland, saying you’ve “got a VQF license” doesn’t mean the government has handed you a shiny certificate. What it really means is that you’ve stepped into a self-regulating club — the VQF — and agreed to live under its constant gaze. This club gathers non-bank financial players and holds them to the fire when it comes to anti-money laundering and counter-terrorist financing rules.
The VQF itself — full name Verein zur Qualitätssicherung von Finanzdienstleistungen — has the blessing of FINMA, the national financial watchdog. But here’s the twist: it’s not a state license office. You don’t get a golden ticket; you get membership, and with it, a permanent chaperone.
In this text I’ll keep calling it “getting a VQF license in Switzerland,” simply because it’s the language the market understands. But don’t be fooled — what you’re really signing up for is a compliance lifestyle. It’s about proving you can identify every client and beneficiary, weigh the risks, watch every transaction, raise a flag when something smells wrong, and be ready for an audit on any given Tuesday morning.
Membership is more than a stamp on paper. It’s a signal that your company has baked compliance into the everyday grind. For fintechs, crypto exchanges, payment platforms, and other non-bank actors, this is the way in — a legal route to operate in Switzerland without begging FINMA for a separate license. The trick is in placing your business correctly under the Anti-Money Laundering Act (AMLA). Do it right, and you move freely. Get it wrong, and you risk being shoved into the wrong box, with all the bans and penalties that follow.
That’s why preparing an application isn’t just about filling forms. You need a clean ownership map, a business model that makes sense, and paperwork that shows you’re not just compliant on paper — you’re ready for the regulator’s flashlight in real life.
VQF Licensing and the Machinery of Supervision
Think of the VQF as Switzerland’s compliance gatekeeper. It has the official blessing of FINMA but runs as an SRO — a self-regulatory organization. Its power isn’t in handing out permits, it’s in watching. Joining means you’ve chosen surveillance instead of silence.
The Swiss system leaves you with no middle ground: if you act as a financial intermediary, you’re either under FINMA directly or you join an SRO like VQF. No grey markets, no hiding in the cracks. The law itself defines who falls into the net, what “professional activity” really means, and the minimum rules you have to play by. From there, the SRO sharpens those rules into its own handbooks and makes sure you follow them.
When you apply, the scrutiny starts immediately. They don’t just skim your documents; they test your AML officers, dissect your policies, and check if your procedures actually run. And once you’re in, the spotlight never leaves. Regular reviews, document checks, theme-based inspections, endless requests for clarifications — plus deadlines to fix whatever doesn’t meet the mark. On top of that, independent AML audits are brought in to see if your daily work really matches your promises.
FINMA, for its part, keeps its eye on the SROs themselves — making sure these clubs don’t slack off and that their members truly live by the AML law. The day-to-day policing sits with the SRO; the ultimate guarantee sits with FINMA. It’s a layered system: cheaper than having the state micromanage every small operator, but still unforgiving when it comes to sloppy compliance.
Who Actually Needs a VQF License in Switzerland
The VQF license isn’t a shiny badge you frame on your office wall — it’s a ticket that tells regulators you’re allowed to touch client money (or digital assets) without having FINMA breathing down your neck directly. If you’re in Switzerland and you move funds for people, but you don’t hold a banking license, this is the umbrella that keeps you dry. It’s what closes the AML/CTF obligations and gives you the legal base to accept, transfer, and distribute money inside your chosen model.
Here’s who has to get in line:
- Payment providers. If your business takes money from a payer and shoots it off to a recipient without opening deposits — think acquiring companies, remittance services, or bulk payout operators — VQF membership is your doorway.
- Payment aggregators for e-commerce. Marketplaces and online platforms that pool seller revenue and later distribute it through segregated bank accounts can’t just wing it. They need that Swiss financial activity license through VQF.
- Limited-scope e-wallets. Digital wallets that park client balances on separate bank accounts and execute payment orders within set limits also fall into the VQF net.
- Currency exchangers. Cash desks, online FX providers, or anyone converting fiat into fiat (without getting into derivatives or leveraged trading) must register. Whether you swap francs for euros at a counter or dollars for pounds online, you’re inside the VQF frame.
- Crypto services (VASPs). This includes OTC desks, crypto brokers, fiat-to-crypto and crypto-to-crypto exchanges, custodial wallets, and even token sale operators who take investor money. If you’re handling crypto in Switzerland, VQF is your compliance gate.
- Non-bank escrow operators. Holding client money in conditional accounts until the contract event happens? Then releasing it? That business model also needs VQF clearance.
- Factoring and collection services. If you take payments from debtors and funnel them to clients under factoring or collection agreements — and you don’t have a banking license — you’re under supervision here too.
- Cross-border remittance providers. Intermediaries moving funds across jurisdictions on an agency model, leaning on correspondent accounts of their partners, need VQF membership to keep things legal.
- Family offices and narrow-scope wealth managers. Even if you only manage money for a small circle of individuals under private mandates — no public fundraising — you’re still under AML/CTF obligations once you handle funds. That means you need the VQF stamp.
- Foreign companies with Swiss presence. Branches and rep offices of non-resident firms that process financial transactions out of Switzerland fall squarely under national AML rules — and must join VQF to stay compliant.
Drawing these lines isn’t just bureaucratic nitpicking. It helps each business model figure out how regulators will classify it — and what compliance muscle it needs to build before even filing for the license.
VQF Approval vs. FINMA Authorization: Where the Line Is Drawn
Getting a VQF license in Switzerland is stepping into the world of self-regulation. It satisfies AML/CTF requirements for financial intermediaries that don’t fall under prudential licensing. FINMA authorization, on the other hand, is reserved for institutions whose activities carry balance-sheet risks or systemic impact. That’s why FINMA demands capital buffers, governance frameworks, and heavy-duty, permanent supervision. The dividing line? It’s the nature of your operations and how deeply you handle client money.
SRO oversight is enough if your role is narrow: you accept, transmit, or distribute funds or digital assets without pulling them onto your own balance sheet, without managing portfolios at your own discretion, and without pooling them into collective investments. In that model, client money stays segregated in partner bank accounts, compliance is about KYC, risk monitoring, and suspicious-activity reporting, and audits come from the SRO. No capital or liquidity thresholds are imposed — because you’re not in the business of holding the risk yourself.
But a VQF license is not enough when your business model slides into the banking or investment lane. The red zone includes: taking deposits from the public with repayment risk, running full-blown banking services, discretionary asset management, acting as a securities dealer, or operating collective investment schemes. In that territory, FINMA steps in, and the rules escalate — own funds requirements, management structure, detailed reporting, and continuous regulatory oversight. That’s where banks, fintech license holders, custodians, and fund managers sit.
The danger comes with misclassification. If you present yourself as an SRO-type intermediary, secure a VQF license in Switzerland, but in reality accept deposits on your balance sheet, promise returns, shuffle client money with lending elements, trade in your own name while executing client orders, or exercise discretion over assets — you’ve crossed the line. Signs like incomplete flow charts, blurred account structures, contracts that fail to ban use of client funds, or commingled accounts create the appearance of banking or investment activity. And the consequences are heavy: orders to stop business immediately, forced transition to full licensing, administrative fines, even criminal liability for unauthorized activity, plus restitution obligations to clients.
The true border between VQF membership and FINMA authorization is found in the substance tests:
- Does control over the money stay with the client, or shift to you?
- Is there an obligation of repayment with default risk?
- Do you hold power to make investment decisions on the client’s behalf?
- Are you engaged in systematic trading for third-party accounts?
- Are you forming a pooled investment structure with a common strategy?
If any of those answers is “yes,” you’re in FINMA territory. If not — if you’re simply a conduit with segregated accounts, transparent KYC, and purely technical execution — then VQF membership covers you.
The Documentation Package
Think of the VQF application dossier as your company laid bare on paper. It’s not just forms; it’s the story of your business, your ownership, your controls, and your daily readiness to play by Switzerland’s AML/CTF rulebook. The SRO wants to see whether your operation is real, structured, and defensible under scrutiny.
Here’s what usually goes inside:
- VQF membership forms. The basics: company details, services, where you operate, how the money flows, which banks you use, and who’s in charge. Plus a signed assurance that the information is true and that AML/CTF responsibilities are properly assigned.
- Business model description. A map of your role in the financial chain: how client funds are held and segregated, who your partners are, what fees you charge, your expected volumes, and the type of clients you’ll serve. Crypto services must go deeper — token types, custody methods, and how you meet the Travel Rule.
- Beneficial ownership and structure. A full diagram down to the human beings behind the company. Copies of trust or nominee agreements if any, ID documents of the ultimate owners, statements about the source of their wealth, and how exactly their rights of influence are structured.
- Key people and governance. CVs of directors and managers, proof of education and training, AML/CTF certificates, clean criminal records, declarations of no conflicts of interest, and board resolutions showing who does what.
- AML/KYC policies. Client onboarding rules, risk classification methodology, CDD/EDD procedures, ongoing monitoring, retention periods, treatment of politically exposed persons, sanctions checks, and your documented approach to high-risk jurisdictions — all signed off by the board with version control.
- IT security and data protection. Access rights matrices, audit logs, backup and incident response plans, encryption requirements, change-management protocols, vendor assessments, and GDPR/FADP data-transfer policies. If you use remote onboarding, for obtaining a VQF license in Switzerland, you’ll need to describe your video-identification process and anti-spoofing tests.
- Client file templates and UBO package. Sample forms for identity checks, beneficiary questionnaires, source-of-funds disclosures, risk assessment sheets, PEP self-declarations, sanctions checklists, data-processing consents, and standard service contracts with annexes.
- Illustrative case studies. Anonymized onboarding files across different risk levels, monitoring logs with analysis, and declined applications with documented reasons.
- Training and competence evidence. The package includes an annual training plan, attendance lists, testing protocols, and course programs. For obtaining a Swiss financial services license, it must also contain certificates from training providers and documented records of ongoing professional development for the AML officer and board members.
- Organizational structure. An organigram, job descriptions with delegated powers and backup rules, compliance calendars, second-line control plans, and a clear division of duties.
- External agreements and confirmations. Contract with the ombudsman (under FinSA), confirmation letters from banks about segregated client accounts, engagement with an AML auditor, and — if relevant — contracts with payment and card partners.
- Legal and financial information. Commercial register excerpt, articles of association, board resolutions, proof of address, tax IDs, financial statements or opening balances, and liability insurance if the model requires it.
- Payments and declarations. Receipts for membership fees, plus any extra declarations the VQF asks for.
- Extra for VASPs. Wallet management policies, hot/cold storage split, blockchain analytics integration, on-chain sanctions screening, whitelisted address mechanics, and controls against unauthorized transfers.
All of this together forms the SRO’s picture of your company: who owns it, who runs it, how risks are managed, and whether the processes on paper are ready to hold up the day you register for a VQF license in Switzerland.
The Process of Getting a VQF License in Switzerland
The road to a VQF license isn’t about filing a form and waiting for a stamp. It’s a choreographed sequence of steps designed to prove, from day one, that your organization can live under AML/CTF rules without slipping. Each stage is about showing the SRO that your business model, your controls, and even your people are ready to withstand the spotlight.
It starts with mapping your products, money flows, and counterparties — and marking the places where compliance risks can pop up. That map is then compared against your internal policies, producing a “gap list” and a plan with deadlines to fix it. AML officers are nominated, the organigram finalized, escalation paths drawn.
Crypto services have extra homework: documenting custody of digital assets, implementing the Travel Rule, and wiring in blockchain analytics. Preparation ends with test onboardings across different risk profiles and staff training, with results logged as proof.
The official Swiss VQF registration forms demand precision: same spelling everywhere, consistent references, attachments properly linked. Your business model must be shown as a clean sequence — sources of funds, how money moves, commissions, partners, payment rails. Into the file go AML/KYC policies, client-file templates, UBO data, résumés of key managers, and qualification proofs.
Foreign documents get translated, apostilled if needed, and all copies notarized. Finally, everything is numbered and sealed as a single dossier, with one contact person named for the SRO.
No money, no review. Once the scope is agreed, the SRO issues an invoice for the joining fee. Payment has to be made via bank transfer with the correct reference. The receipt is attached to the file; without it, the review stalls.
The SRO’s secretariat checks the dossier for completeness and consistency, then runs your model against the AMLA framework and the SRO’s own standards. They focus on ownership structure, independence of governance bodies, and whether the promised procedures look real, not theoretical. Borderline models may trigger an additional check to see if FINMA authorization is required instead.
Expect back-and-forth. VQF often asks for proof of segregated client funds, evidence of owners’ wealth sources, or IT control robustness. Contracts with ID providers, monitoring samples, even investigation logs may be requested.
Answers must be structured, tied point-by-point to the request, version-marked, and timely. Delay the response and the whole review drags — sometimes leading to repeat queries.
After analysis, the SRO issues one of three outcomes:
- Acceptance of Swiss VQF license — you’re in, with a registration number and a supervision scheme, including an AML auditor.
- Conditional acceptance — you’re admitted, but only if you fix specified issues within deadlines and provide proof.
- Refusal — with reasons. After fixing them, you may reapply.
Membership is not the end, it’s the start of oversight. From here, you’re obliged to:
- File periodic reports
- Undergo thematic reviews
- Keep AML/KYC policies updated
- Re-train staff and refresh client files on schedule
- Notify the SRO of ownership or business model changes
Communication channels are tested for responsiveness, monitoring logs must run continuously, and preparations for the first external AML audit begin — with sample transactions and evidence storage checked for integrity.
Taxes After Licensing
Once licensed, your institution also steps into the Swiss tax regime. The federal corporate tax rate is 8.5%. With cantonal CIT added, the total rate runs from 11.9% to 20.5%, depending on your location. A capital gains levy applies in the same band. Withholding taxes run 0–35% on interest and dividends, and up to 0% on royalties depending on structure.
Contact our experts and get answers to your questions.
Conclusion
A VQF license in Switzerland pays off only if your business model matches AMLA’s expectations and your internal controls aren’t just words on paper. Professional guidance helps uncover vulnerabilities early, align fund flows correctly, formalize segregation in bank agreements, and lock in a provable chain for owners’ capital.
A seasoned advisor makes the first external audit smoother, systematizes evidence storage, and cuts down the risk of nasty regulatory surprises. And even after licensing, that support is vital: updating policies on time, reacting to sanctions-list changes, and fine-tuning tech solutions without breaking compliance routines.
