Where the regimes diverge
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The following table sets out the points at which a group cannot apply one rule to both entities without choosing. In each row the group must decide whether to apply the stricter standard throughout or to run two standards with a documented boundary.
| Topic | Singapore (PSN02, CDSA) | Switzerland (AMLA, AMLO-FINMA, SRO regulations) | Group approach |
|---|---|---|---|
| CDD threshold for occasional exchange transactions | None, CDD for every DPT transaction | CHF 1,000 for exchange of crypto assets (Art. 51a AMLO-FINMA, SRO equivalents) | Apply Singapore rule (no threshold) group-wide if systems permit |
| Beneficial owner threshold | Control-based, 25% as practice | Controlling person 25% (Art. 2a para. 3 AMLA), Form K/A declarations | Common 25% with control override, Swiss forms used in both entities |
| PEP definition | Foreign PEP always EDD, domestic and international-organisation PEP risk-based | Same structure (Art. 2a paras 1–2 AMLA), foreign PEP always high risk | Common definition, common EDD |
| Record retention | 5 years | 10 years (Art. 7 para. 3 AMLA) | 10 years group-wide |
| Travel rule information set | Reduced set below S$ 1,500 | Full set always | Full set always |
| Unhosted wallets | Risk-based, verification encouraged | Proof of control required | Proof of control required group-wide |
| Reporting standard | Knowledge or reasonable grounds to suspect, s. 45 CDSA | Reasonable suspicion (begründeter Verdacht), Art. 9 AMLA, as lowered by BGE 147 IV 274 | Common escalation, two filing procedures |
| Freeze after report | No automatic freeze, firm's risk decision | Freeze only once MROS notifies within 40 working days (Art. 10 AMLA, Art. 23 para. 5 AMLA) | Jurisdiction-specific |
| Tipping-off | s. 57 CDSA, no statutory group exception | Art. 10a AMLA, with intra-group exception (para. 3) | Protocol in Section 6 below |
| Sanctions | UN plus Russia measures, OFAC commercially | UN plus full EU alignment | Jurisdiction-specific screening lists, common process |
| AML audit | Independent audit function plus annual auditor report to MAS | Annual AML audit by SRO or licensed audit firm | Coordinated audit calendar, shared findings register |
The pattern is that Singapore is stricter at onboarding (no threshold, CDD for every transaction) and Switzerland is stricter on transfers and retention (full travel-rule set, proof of control, ten years).1 A group that adopts the stricter rule in each row ends with a programme that exceeds both regimes and can be defended before either regulator as such. The cost is borne by the customer in friction and by the firm in systems. In my experience most groups accept the cost, because the alternative, two standards with a boundary, produces exactly the inconsistencies that inspectors find first.
Notes
- AMLA, Art. 7 para. 3 (ten-year retention), Art. 2a paras 1–3 (definitions of politically exposed persons and controlling persons); AMLO-FINMA, Art. 51a (CHF 1,000 threshold for exchange transactions in crypto assets, lowered from CHF 5,000 with effect from 1 January 2021); VQF, Regulations and Forms A, K, S and T for the establishment of beneficial owners and controlling persons. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.