Fractional AML Compliance Officer Support in Switzerland
Running an AML compliance program is ongoing work. Businesses that do not need a large in-house compliance team may still need reliable, recurring AML capacity: someone keeping the workplan moving, applying controls consistently, and following remediation through to completion.
ComplyFactor provides fractional and outsourced AML compliance officer support to financial intermediaries, portfolio managers, trustees and other AML-obliged businesses in Switzerland, supplementing an internal compliance officer or providing recurring external capacity where the work has outgrown current resources.
We scope every engagement around your actual regulatory status and organizational setup, so the support we provide is structured correctly from the outset.
What Is Fractional AML Compliance Support?
Fractional AML compliance support is recurring, external compliance capacity rather than a one-off report or advice alone. ComplyFactor helps keep your AML compliance program moving by applying controls consistently, maintaining documentation, tracking open items, and giving management the information it needs to oversee the program. Advice tells a business what to fix; fractional support helps keep the fix, and the program around it, running.
Advice
Identifies what should change.
Ongoing Support
How We Support Your AML Compliance Function
Our work can include program coordination, maintaining an AML workplan and a recurring compliance calendar so tasks don't slip, and keeping policies and procedures aligned with how the business actually operates rather than left to drift from operational reality. On the risk side, we can support maintenance and practical application of the AML risk analysis, and help teams apply CDD, KYC and EDD processes consistently across customer files. We can review control evidence and monitoring outputs, track open issues and remediation actions through to closure, and prepare the management information and governance reporting your business needs to oversee the program. Where relevant, our work can also include coordinating training and internal compliance communication, and supporting the implementation of regulatory change as it reaches your specific business.
Program Coordination
AML workplan and recurring compliance calendar.
Controls & Procedures
Policy and procedure maintenance, aligned with actual operations.
CDD / KYC / EDD Support
Consistent application of customer due-diligence processes.
Monitoring & Remediation
Control evidence review, issue tracking, remediation through to closure.
Governance & Reporting
Management information and governance reporting.
Training & Change Implementation
Internal compliance coordination and regulatory-change implementation, where relevant.
Where External AML Compliance Support Fits
External support can work as a supplement, sitting alongside an internal AML compliance officer during busy periods or capability gaps, or as recurring capacity for a smaller institution that does not want a large in-house team. It can also be scoped narrowly, to a single workstream such as CDD remediation, or to a defined period, such as while a business integrates a recent change.
Supplement
Internal team plus external AML capacity during busy periods or capability gaps.
Recurring Capacity
Defined ongoing workstreams without building a large in-house team.
Focused Workstream
Scoped narrowly to one area, such as CDD remediation.
Defined Period
Support through a specific period of business change.
Not every formal compliance role can be outsourced in every case; the permissible model depends on the business's entity type and applicable supervisory framework.
When Fractional AML Support Makes Sense
Businesses typically reach out when:
Compliance workload has outgrown internal capacity
Remediation from a gap analysis or independent review needs sustained follow-through to close out
Management wants more structured, recurring AML reporting
Regulatory or business change has created additional compliance work
Policies exist on paper but implementation has become inconsistent in practice
How We Define Responsibilities Between Your Team and ComplyFactor
We first determine which supervisory framework applies to your business, then define what can be supported externally and what must remain within your organization. This matters because FINMA has been explicit that responsibility for an outsourced function, including risk management and compliance, stays with the institution. FINMA's 2026 guidance on portfolio management flagged cases where outsourcing to external providers produced standardized controls, not institution-specific ones, and unclear responsibilities.
Your Organization
ComplyFactor Support
We structure support so that your business retains the resources, information access and oversight it needs, responsibilities are agreed and documented up front, and management and the governing body keep the duties the applicable framework places on them. Our role is to make those responsibilities easier to discharge well.
External support does not automatically transfer regulatory responsibility away from your organization.
How We Structure AML Support Around Your Swiss Regulatory Status
The right operating model differs by entity type. We confirm which framework applies to you and what it permits before we define scope.
FINMA-Supervised Institutions
Direct supervision, with entity-specific outsourcing requirements.
Portfolio Managers / Trustees
FINMA licence, with ongoing supervision through an SO where applicable.
SRO-Affiliated Intermediaries
Support permitted depends on the affiliated SRO's own rules.
Our Approach to Ongoing AML Compliance Support
Determine Your Regulatory and Organizational Context
Confirm entity type and supervisory route before defining anything else.
Define the Permitted Support Model and Where Responsibility Sits
Agree what can be supported externally and what must remain internal.
Prioritize Current AML Workstreams
Establish what needs attention first, based on risk and existing findings.
Establish a Recurring Support Cadence and Governance Rhythm
Set the pattern for ongoing work and reporting.
Support Execution and Monitoring
Apply controls, review evidence, and keep work moving.
Track Issues and Remediation to Closure
Maintain a live record of open items and their status.
Report Material Matters to Agreed Internal Stakeholders
Keep management and the governing body informed as agreed.
What You Receive
Depending on scope, this can include:
Responsibility Matrix
AML Workplan & Calendar
Action & Issue Tracker
Remediation Tracker
Management Reporting
Choosing the Right ComplyFactor Service
Why Businesses Use ComplyFactor for Ongoing AML Support
Clearly Defined Responsibilities
No ambiguity about who owns what, from the outset.
Entity-Specific Scoping
Scoped to each entity type.
Recurring Implementation Support
Support continues after the policy documents are written.
Documented, Trackable Workstreams
Work is documented and reviewable.
Risk-Based Prioritization
Attention goes where it matters most first.
Management Visibility
Structured reporting to management.
Tailored to Your Control Environment
Scope reflects what your business runs today.
Clear Separation From Independent Testing
Where both are relevant, operational support and independent review stay distinct roles.
Swiss AML Requirements Have Changed
Revised AMLA
The revised AMLA entered into force on 1 October 2026.
Transparency Framework
The new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners also entered into force on 1 October 2026.
AMLO-FINMA Revision
The AMLO-FINMA consultation closed on 9 June 2026. FINMA has not yet published the final revised ordinance, so those proposals should not be treated as current requirements.
Ongoing compliance support should reflect the changes already in force as they apply to your business.
Frequently Asked Questions
Can fractional AML support cover only one compliance workstream?
Yes. We can scope support narrowly, for example to CDD remediation, risk-analysis maintenance, or monitoring, rather than the full program. Scope can also be widened later if your needs change.
What information do you need before defining the scope of support?
We typically start with your entity type and supervisory status, current AML policies and procedures, an outline of your existing compliance resourcing, and any open findings from a prior review or gap analysis. This lets us define a realistic scope and responsibility split before work begins.
Can ComplyFactor work with our existing compliance officer, legal counsel or Swiss adviser?
Yes. Fractional support is commonly structured to work alongside your existing team and advisers, with responsibilities agreed between everyone involved rather than assumed.
Can the level of AML support increase or reduce as our workload changes?
Yes. Support is typically structured to flex with workload, for example scaling up during a remediation program or a period of business change, and scaling back once things stabilize.
Need Ongoing AML Compliance Capacity in Switzerland?
Speak with ComplyFactor about your regulatory status, current compliance structure and where you need recurring external support. We'll help define a scope that reflects what can be supported externally and what needs to stay within your organization.