Legal Advice to a FinTech Start-up on the Structuring and Launch of a Swiss AML-Compliant Payment Platform (including SRO Affiliation)

Zürcher Rechtsanwälte AG provided comprehensive regulatory advice to a Swiss FinTech Start-up on the development and legal structuring of an innovative payment platform. The platform enables individuals and legal entities to settle invoices for goods and services - such as rent, insurance, or taxes - by credit card. By using credit cards, users benefit from bonus points, rewards, and miles offered by the credit card providers, which can be redeemed for special promotions, travel, hotel stays, or flights.

As a result of operating the payment platform, the FinTech Start-up qualifies as a financial intermediary in the Swiss parabanking sector pursuant to Art. 2 para. 3 of the Swiss Anti-Money Laundering Act (AMLA) and is therefore subject to Swiss AML-Regulation. Zürcher Rechtsanwälte AG advised the client on its regulatory classification, supported the submission of the application for affiliation with a recognised self-regulatory organisation (SRO), and prepared all required compliance documentation, in particular the AML guidelines.

Furthermore, Sebastian Hepp, attorney-at-law and partner at Zürcher Rechtsanwälte AG, was appointed as external Compliance Officer. In this role, he provides ongoing support to the FinTech Start-up in implementing and maintaining AML compliance, notably in relation to client onboarding, KYC procedures, and transaction monitoring. 

Sebastian Hepp (Partner, Financial Market Law/Regulatory Compliance) acted as lead counsel for the legal structuring and launch of the payment platform and for the successful submission of the SRO affiliation application.