finma RS2016/7
FINMA RS2016/7
FINMA Circular 2016/7 – Permitted Procedures for Establishing Business Relationships via Correspondence
FINMA Circular 2016/7 defines three procedures that are permissible for initiating business relationships via correspondence, “provided they are carried out in accordance with one of the following methods and in compliance with the requirements set out in margin nos. 32–37, 38–39, and 40–41.”
Electronic ID copy with authenticity verification by the financial intermediary (Online identification via NFC or bank transfer + proof of residence) ➡️ Margin nos. 32–37
Electronic ID copy with qualified electronic signature (QES) (Simple copy + QES, explicitly without proof of residence) ➡️ Margin nos. 38–39
Digital authenticity confirmation (Electronic confirmation of authenticity + proof of residence) ➡️ Margin nos. 40–41
Applicable Provisions for QES
We provide services in accordance with FINMA Circular 2016/7, specifically under the procedure “Electronic ID copy with qualified electronic signature” (RS2016/7, margin no. 38).
RS2016/7, Margin no. 38 The financial intermediary obtains, via an electronic channel, an electronic copy of all relevant pages of the identification document from the contracting party, along with its authentication through a qualified electronic signature issued by a certification service provider recognized in Switzerland, in accordance with the Federal Act on Electronic Signatures (ZertES; SR 943.03).
👉 We provide a qualified electronically signed copy of the ID document in PDF format. The financial intermediary can independently verify the validity of the QES at any time (e.g. via Adobe Acrobat or validator.admin.ch).
RS2016/7, Margin no. 39 The financial intermediary verifies the consistency of the data shown on the ID document with that contained in the qualified electronic signature.
👉 This verification is performed automatically during the identification process, ensuring full compliance with this requirement. Banks may, for instance, conduct sample checks at any time by reviewing the PDF.
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