Compliance Framework
Anti-Money Laundering (AML) Policy
SwissTrustOne maintains a zero-tolerance policy toward money laundering, terrorist financing, and all forms of financial crime. Our AML framework is designed to meet and exceed the standards set by the Financial Action Task Force (FATF), the Swiss Anti-Money Laundering Act (AMLA), and applicable international regulations.
Know Your Customer (KYC) Requirements
All clients are subject to rigorous identity verification before accessing SwissTrustOne services. Our KYC process includes: verification of government-issued photo identification; proof of residential address dated within 90 days; source of wealth and source of funds documentation; beneficial ownership declaration for corporate entities; and enhanced due diligence for Politically Exposed Persons (PEPs) and high-risk jurisdictions. KYC documentation is reviewed and refreshed on a risk-based schedule, with high-risk clients reviewed annually.
Risk-Based Approach
We apply a risk-based approach to AML compliance, categorizing clients and transactions according to assessed risk levels. Risk factors considered include: client type and business activity; geographic risk (jurisdiction of residence and fund origin); transaction patterns and volumes; nature of the investment products accessed; and adverse media and sanctions screening results. Enhanced due diligence is applied to all high-risk relationships, with additional monitoring and senior management approval required for onboarding.
Transaction Monitoring
SwissTrustOne employs automated transaction monitoring systems that analyze all client activity against established behavioral baselines and regulatory thresholds. Alerts are generated for: transactions exceeding CHF 15,000 or equivalent; unusual patterns inconsistent with stated investment objectives; rapid movement of funds without clear economic rationale; transactions involving high-risk jurisdictions; and structuring activity designed to evade reporting thresholds. All alerts are reviewed by our compliance team within 24 hours.
Sanctions Screening
All clients, beneficial owners, and counterparties are screened against international sanctions lists including OFAC, EU Consolidated List, UN Security Council Sanctions, Swiss SECO list, and HM Treasury Consolidated List. Screening is conducted at onboarding and on an ongoing basis with daily list updates. Any match triggers an immediate account freeze and escalation to our Chief Compliance Officer. We do not conduct business with sanctioned individuals, entities, or jurisdictions.
Suspicious Activity Reporting
SwissTrustOne is legally obligated to report suspicious transactions to the Swiss Money Laundering Reporting Office (MROS) and relevant authorities in applicable jurisdictions. Our compliance team is trained to identify and escalate suspicious activity indicators. Reports are filed within the legally required timeframe. Clients are not informed of suspicious activity reports filed against them (tipping-off prohibition). We cooperate fully with law enforcement and regulatory investigations.
Staff Training & Governance
All SwissTrustOne employees undergo mandatory AML training upon joining and annually thereafter. Training covers regulatory requirements, red flag identification, internal reporting procedures, and consequences of non-compliance. Our Chief Compliance Officer holds ultimate responsibility for AML program oversight, reporting directly to the Board of Directors. An independent AML audit is conducted annually by external specialists. Any employee who facilitates financial crime is subject to immediate termination and referral to authorities.
Record Keeping
We maintain comprehensive records of all KYC documentation, transaction records, monitoring alerts, and compliance decisions for a minimum of 10 years as required by Swiss law. Records are stored in encrypted, access-controlled systems with full audit trails. In the event of a regulatory inquiry or law enforcement request, records are produced promptly in accordance with applicable legal procedures. Record destruction is conducted only upon expiry of mandatory retention periods and with documented authorization.
Compliance Inquiries
To report suspicious activity or for AML-related inquiries, contact our Chief Compliance Officer at compliance@swisstrustonegroup.com. All reports are treated with strict confidentiality.