Documentation gap
Without a clean audit trail per employee and module, compliance officers have to prove manually during an audit who completed what and when – usually with Excel lists that are already out of date by the time the audit comes around.
FINMA categories 1 to 5 · CDB 20
AMLA training for FINMA-regulated financial institutions
Why generic compliance training is not enough for banks
Most providers on the market – whether specialised compliance platforms or broad L&D providers with cyber security, data protection and occupational safety in their portfolio – treat the AMLA as one topic among many. The result is superficial content without any direct reference to the CDB 20, which does not formally stand up to a FINMA audit because it does not even refer to the bank-specific legal basis.
Focus on FINMA
Focus on FINMA
Banks in FINMA categories 1 to 5 are directly subject to the CDB 20 (Agreement on the Swiss Banks’ Code of Conduct with regard to the Exercise of Due Diligence) – a set of rules that prescribes its own bank-specific due diligence articles and goes beyond the general AMLA provisions. Anyone relying on generic compliance training here risks gaps at the next FINMA audit that can become expensive.
FinReg Swiss was built consistently for exactly this case: 100% Swiss regulation, no adapted EU training, no generic multi-topic course.
Two concrete consequences in practice
Content gap
Training content based on EU anti-money laundering law or generic Swiss material does not cover CDB 20-specific obligations such as the qualified identification of the contracting party or the documentation requirements for higher risks – even though that is exactly what is audited.
Course content
6 modules – no topic left out.
Each module: approx. 15–20 minutes, video-based, with a knowledge test and an automatic certificate.
1
Module 1
Introduction to Anti-Money Laundering
A solid introduction to the fundamentals of combating money laundering. Learn the legal framework and the key concepts that are essential for day-to-day practice in the Swiss financial sector.
In this module, you'll learn:
- Fundamentals of money laundering in Switzerland
- Legal framework (AMLA, FINMA)
- Stages of money laundering
- Practical case studies from Switzerland
2
Module 2
Identification of the Contracting Party
Learn how to identify contracting parties correctly and in a legally sound manner. From document verification to ongoing monitoring – all key aspects of customer identification under the CDB.
In this module, you'll learn:
- Identification duty under Art. 3 AMLA and CDB 20
- Source of Wealth (SoW) vs. Source of Funds (SoF)
- Accepted documents
- Face-to-face vs. non-face-to-face identification
3
Module 3
Identification of the Beneficial Owner
Explore the complex world of beneficial ownership. Learn how to identify and document the actual controlling persons – a key element in the fight against money laundering.
In this module, you'll learn:
- Establishing the beneficial owner of natural persons and legal entities
- The 25% threshold and how to apply it
- Forms A, T, K, I and S (different legal structures)
- Re-identification in case of doubt
4
Module 4
Enhanced Due Diligence
Deepen your understanding of higher risks in banking. From PEPs to complex structures – understand when additional clarifications are required and how to carry them out.
In this module, you'll learn:
- Politically exposed persons (PEPs): criteria and categories
- Enhanced due diligence and annual review
- Higher-risk business relationships and transactions
- Plausibility checks: origin, purpose and background of payments
5
Module 5
Documentation Obligations
Learn the essential requirements for legally compliant documentation. Find out how to document your clarifications and decisions in a traceable, FINMA-compliant way.
In this module, you'll learn:
- Creating, organising and retaining documents
- 10-year retention obligation under the AMLA
- Transparency for FINMA audits (zero tolerance)
- Accessibility and labelling for third parties
6
Module 6
Digital Assets
Dive into the world of digital assets. Find out which particular challenges cryptocurrencies and other digital assets pose for anti-money laundering.
In this module, you'll learn:
- Fiat money vs. cryptocurrencies (Bitcoin, Ethereum)
- Regulated vs. unregulated exchanges
- Coin mixers and obfuscation methods
- Risk assessment for crypto transactions
Audit trail & monitoring
FINMA audits without the stress
Every completed module is automatically documented in the audit trail. At your next FINMA audit, your complete compliance report is available in minutes instead of days. Monitoring and reminders run automatically – nobody in the compliance team has to manually track who has not yet met their annual training obligation.
Matching pricing tier: The same transparent pricing applies as for all clients. View full pricing
FAQ
FAQ for FINMA-regulated banks
Does the training fully cover the CDB 20?
Yes. All six modules have been developed with direct reference to the relevant CDB 20 articles, in particular Module 2 (identifying the contracting party) and Module 3 (beneficial owners).
Is the training sufficient as evidence in a FINMA audit?
Every completion is automatically documented in the audit trail and is available at any time as a report for the FINMA audit – without any manual rework.
How does the bank version differ from the SRO version?
The bank version consistently refers to the CDB 20, which does not apply to SRO-regulated financial intermediaries. SRO-regulated firms will find the right solution on our SRO page.
How long does implementation take?
You send us your employee list, we set up the accounts, and access is live within 8 hours. No IT effort on your side.
Is the training also available in English?
Yes, both German and English are included in the price. Employees choose their language themselves.
Not the right segment?
→ Are you SRO-regulated (VQF, VSV, ASG)? SRO solution→ Do you second or place compliance staff? Staffing solution
