SOMREMIT GMBH · SWITZERLAND

Anti-Money Laundering &
Counter-Terrorist Financing Policy

A public summary of the compliance requirements governing our money transfer services.

1. Scope and regulatory framework

Somremit GmbH is a member of PolyReg, a Swiss self-regulatory organisation recognised by FINMA. Our money transfer activities are subject to the Swiss Anti-Money Laundering Act (AMLA / GwG), applicable implementing provisions and PolyReg rules. Membership does not constitute a banking licence or a guarantee of individual transactions. Transfers can be initiated from Switzerland only, to supported destinations.

2. Customer identification and beneficial ownership

Our AML framework requires identification of the customer and, where applicable, authorised representatives, beneficial owners and controlling persons. Customers must provide reliable identification and disclose when acting for someone else. Business customers may need registration and ownership documents. Anonymous or fictitious identities cannot be used to bypass these requirements.

3. Purpose, source of funds and source of wealth

Customers may be asked to explain the transfer purpose, their relationship with the recipient and the lawful source of funds. Supporting evidence and, where justified by risk, information on source of wealth may be required. Deliberately splitting transactions to avoid compliance checks is not permitted.

4. Sanctions and PEP screening

The compliance framework includes checks for applicable sanctions and politically exposed persons (PEPs), including relevant beneficial owners and recipients. Potential name matches require clarification; a match alone does not establish wrongdoing. PEP status may require enhanced due diligence and appropriate approval. Applicable Swiss sanctions must be observed. Additional restrictions can apply through payment partners or receiving-country law.

5. Risk assessment and transaction review

Customers and transfers are assessed according to relevant risk factors, including destination, amount, payment method and transaction patterns. Higher-risk or unusual activity requires further clarification and documentation. FATF country-risk information informs this assessment; a country listing is not automatically a blanket prohibition. Customer information must be kept current where required.

6. Escalation and suspicious activity reporting

Unresolved concerns are subject to compliance review. Where the legal reporting threshold is met, Somremit must report to the Money Laundering Reporting Office Switzerland (MROS). Any asset restrictions and limits on informing affected persons are handled under applicable law. Missing information or legal restrictions may delay or prevent a transfer; customers cannot request that checks be waived.

7. Records, confidentiality and data protection

Identification, transaction and clarification records must be retained for the statutory period and made available to competent authorities when legally required. Access and disclosure are subject to confidentiality and data-protection obligations. See our Privacy Policy. Ask our team how to provide identification documents; do not include passwords or card details in the general enquiry form.

8. Responsibility, training and oversight

The applicable framework requires clear compliance responsibilities, suitable internal controls, staff training and the inspections required by PolyReg. This public summary does not describe confidential screening tools, internal thresholds or escalation procedures. Banking partners may request supporting compliance documentation through an appropriate channel.

9. International standards and service partners

FATF recommendations provide internationally recognised AML/CFT standards. They complement, rather than replace, applicable Swiss requirements. Payment partners and receiving-country requirements may affect a transfer. No service may be used to evade sanctions or disguise unlawful funds.

Contact

Somremit GmbH · Fabrikstrasse 11 · 8005 Zurich, Switzerland
+41 44 911 55 55 · info@somremit.ch

Official references

PolyReg regulations · FINMA AML framework · Swiss sanctions · FATF recommendations

This page summarises the applicable compliance framework. Applicable law and binding PolyReg rules take precedence.