Limited internal capacity
The business needs qualified AML oversight, but the volume does not support a dedicated full-time role.
External compliance mandate
AML oversight that works inside your operations
Symplified provides an external AML compliance function for Swiss financial intermediaries that need experienced oversight without building a full internal department. The mandate is designed around your clients, transactions, systems and supervisory framework.
When an external model makes sense
A practical option for a growing or specialised business
The decision should follow the workload, independence needs and risk profile—not simply headcount.
New regulated activity
The company is establishing its first control framework or preparing for SRO affiliation and operations.
Complex risk exposure
Cross-border clients, payment flows or other higher-risk features require experienced review and escalation.
Coverage
What the engagement can include
The precise allocation is set in writing. This table is a service map, not a one-size-fits-all package.
| Control area | Typical external support | Expected evidence |
|---|---|---|
| Governance and risk | Review the risk assessment, control ownership, escalation paths and management information. | Approved framework, responsibilities and periodic reporting. |
| Client due diligence | Advise on identification, beneficial ownership, higher-risk reviews and complex onboarding questions. | Complete files with recorded rationale and approvals. |
| Ongoing controls | Oversee review schedules, alerts, sanctions processes and remediation follow-up. | Review logs, resolved exceptions and tracked actions. |
| Suspicion handling | Support internal escalation and the assessment of reporting duties under the agreed governance. | Confidential decision records and reporting documentation where applicable. |
| People and awareness | Provide role-specific training and practical guidance for staff and management. | Training materials, attendance and knowledge follow-up. |
| SRO audit readiness | Organise the compliance file, prepare responsible persons and coordinate responses to findings. | Audit index, requested records and remediation plan. |
Governance boundary
The provider operates the mandate; the company governs it
External support does not replace the governing body’s oversight. A workable arrangement identifies reserved decisions, access rights, reporting frequency and the internal person responsible for supervising the provider.
✓Written responsibilities and a clear reporting line
✓Access to the information and people needed for the work
✓Defined escalation deadlines and decision authority
✓Management review of issues, trends and overdue actions
✓Periodic assessment of whether the mandate remains adequate
Working rhythm
A recurring control cycle, not an annual clean-up
The cadence is agreed according to risk and activity. Each cycle produces a record that management can review and auditors can follow.
Baseline review
Confirm scope, gaps, access and immediate corrective actions.
Case oversight
Review referrals, exceptions and higher-risk relationships.
Control reporting
Present issues, trends, decisions and overdue actions.
Framework refresh
Update the risk assessment, policies and training plan.
SRO preparation
Assemble evidence, support interviews and track findings.
Commercial model
A scope based on the work required
Fees depend on the firm’s regulatory status, activities, client population, transaction profile, systems and frequency of support. After a short assessment, Symplified proposes the deliverables, service rhythm and fee in writing.
Request a Mandate ProposalImportant: the applicable SRO regulations and the firm’s specific legal position determine which tasks may be allocated externally and which decisions must remain within the company.
Questions
Before appointing an external AML officer
Is the same mandate suitable for every intermediary?
No. A mandate must reflect the firm’s regulatory category, activities, scale, risk exposure and internal organisation.
Can Symplified support an SRO application as well?
The external function can be coordinated with an SRO application or remediation project. The application and ongoing mandate should nevertheless have separate, clearly stated deliverables.
Who remains responsible for AML compliance?
The company and its governing body retain their legal and supervisory responsibilities. The external provider performs the work allocated under the agreement and reports through the agreed governance.
How quickly can a mandate begin?
Timing depends on the completeness of the existing framework, the availability of records and whether material gaps must be resolved before handover.
Regulatory references: FINMA overview of Swiss AML supervision · fedpol information on MROS. This page describes a service framework and is not a determination that outsourcing is permitted for every firm.
Build an AML mandate around your actual risk.
Tell us how the business operates. We will identify the required coverage, internal responsibilities and implementation priorities.
Speak With Symplified