Switzerland’s Financial Market Supervisory Authority (FINMA) has published Guidance on the regulatory requirements for payments on the blockchain for financial services providers under its supervision. As per the Guidance, blockchain service providers are obliged, for instance, to verify the identity of their customers, to establish the identity of the beneficial owner, to take a risk-based approach to monitoring business relationships and to file a report with the Money Laundering Reporting Office Switzerland (MROS) if there are reasonable grounds to suspect money laundering. Article 10 AMLO-FINMA requires that information about the client and the beneficiary be transmitted with payment orders. The financial intermediary receiving this information then has the opportunity to check the name of the sender against sanction lists. It can also check whether the information for the beneficiary is correct or whether it should return the payment in the event of discrepancies.

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