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AMLA Onboarding and KYC Workflow

Laws as Code

Jurisdiction

Switzerland (Federal)

Primary Rules

Federal Act on Combating Money Laundering and Terrorist Financing (AMLA, SR 955.0); Ordinance on Combating Money Laundering and Terrorist Financing (AMLO, SR 955.01); Ordinance of the Swiss Financial Market Supervisory Authority on Combating Money Laundering and Terrorist Financing (AMLO-FINMA, SR 955.033.0)

Target Audience

Client-facing banking staff

Project Hash ID

#V924

Project Category Name

Eunomia

Business Process Model and Notation (BPMN 2.0) serves as the universal "sheet music" for organizational workflows, utilizing a standardized set of symbols to eliminate ambiguity. By using specific shapes, BPMN enables the mapping of a process as it moves from start to finish. It transforms complex, text-heavy procedures into a clear, scannable map that people can all interpret without needing a "translator".

When applied to legislation like the Swiss Anti-Money Laundering Act (AMLA), BPMN bridges the gap between abstract legal duties and daily banking operations. For instance, the duty to submit a Suspicious Activity Report (SAR) under Art. 9 AMLA is no longer just a paragraph in a law; it becomes a Service Task that triggers a specific "handshake" with the Money Laundering Reporting Office Switzerland (MROS). This mapping ensures that critical legal nuances, such as the mandatory 5-day statutory window and the subsequent Art. 9b Compliance Review, are built directly into the workflow, making compliance a natural byproduct of the process rather than an afterthought.

The true magic happens when a BPMN diagram is "runnable" through execution engines. In this context, the visual process isn't just a passive drawing; it is the actual code that powers an automation system. When the model is deployed, the Event-Based Gateway act as a live logic engine that physically pauses the process to "listen" for a MROS Notification while simultaneously running a 5-Day Timer. If the message arrives, the system routes the user to judicial checks; if the timer hits zero first, the system automatically triggers the next regulatory step. This ensures that the bank's operations are always synchronized with the law in real-time, providing an automated, "audit-proof" trail of every decision made.

Work Steps

Research and legal mapping

The starting point was a review of the primary legal sources, AMLA, AMLO and AMLO-FINMA, to identify the obligations applicable to financial intermediaries in the context of client onboarding and suspicious activity reporting. The key regulatory triggers, including the duty to identify customers, establish beneficial owners, clarify increased risks, and report suspicious activity to MROS, were mapped to their respective legal provisions across all three instruments.

Diagram drafting and iteration

The visual was assembled as a diagram, arranging swim lanes, decision diamonds, and document symbols into a BPMN layout. Several iterations were required to correctly reflect the conditional logic, for instance, the branching at the reasonable suspicion gateway, the parallel notification and freeze obligations, and the timeout path triggered by the five-day MROS response window.

Runnable BPMN

The finalised diagram was produced as a standards-compliant BPMN 2.0 file, directly executable on standard process engines. Each process node, gateway, and sequence flow corresponds to a typed BPMN element, preserving the full conditional logic of the depicted process. The runnable BPMN file enables financial intermediaries and compliance teams to deploy the process directly into their workflow infrastructure and automate execution of the depicted obligations.

Finalization and publishing