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gateSwissAMLA — Swiss Anti-Money Laundering Act (GwG) Gate
// The problem

Two equally valid registration paths mean two places where something can be missed.

Financial intermediaries can either register directly with FINMA or join a self-regulatory organisation (SRO). gateSwissAMLA checks both paths in a hardcoded, deterministic way, regardless of which one was chosen.

Ten-year retention as a Swiss particularity
While most other jurisdictions require five to seven years, Art. 7 GwG mandates ten years, the longest period of any implemented jurisdiction. The gate checks this value independently, not as a generic default.
// Architecture

4 clusters, checked sequentially.

Every cluster is dispositive (material_block_mode: true), a hit blocks bindingly, not merely for documentation.

CLUSTER 1
Registration (FINMA or SRO)
Checks FINMA registration (Art. 2) or alternatively SRO membership (Art. 2(2)), both paths checked on equal footing.
finma_registered OR sro_member
CLUSTER 2
Client Identification & UBO
Checks client identification before a relationship of 15,000 CHF or more (Art. 3) and beneficial owner at 25% or more (Art. 4).
client_id · ubo_25pct
CLUSTER 3
PEP & Risk Classification
Checks PEP screening (Art. 3(3)) and documented risk classification (Art. 5).
pep_screened · risk_classified
CLUSTER 4
MROS & SECO & Retention
Checks MROS filing (Art. 10), SECO sanctions screening, and 10-year retention (Art. 7).
mros_filed_if_required · seco_screened · retention_10y
No case, no doubt
Every cluster returns its own sealed result. A single hit in an active cluster is enough to block the overall action.
// Test results

Two tested scenarios.

All values on this page are fictional test data and serve only to illustrate the gate logic.

Scenario C1C2C3C4 Verdict Latency
Full compliance (11/11)PASSPASSPASSPASSSWISSAMLA_SEALED410ms
4 critical violationsFAILFAILnot evaluatednot evaluatedBLOCK_SWISSAMLA_11_FLAGS497ms
Cryptographic chain continuation
Every test produces a deterministic receipt_id, an input_snapshot_hash, an HMAC-SHA256 signature, and a merkle_link to the previous receipt. Persistence occurs in the gateSwissAMLAReceipt entity with a 10-year retention period.
// Clarification

What gateSwissAMLA is not.

  • Not automatic recognition by FINMA. The gate delivers a cryptographic proof, not regulatory registration confirmation.
  • Not a replacement for the actual MROS filing. The gate seals the pre-check, it does not itself file with the reporting office.

For Swiss financial intermediaries that want to make GwG compliance provable across both registration paths.

GATE CATALOG · REGULATORY DETERMINATION DOMAIN

gateSwissAMLA

gateSwissAMLA determines encoded Swiss AML, party, intermediary and transaction conditions for a defined scope. The gate contributes a bound regulatory determination state; it creates neither regulatory authority nor Execution Permission.

DOMAIN_DETERMINATION_ONLY = true · EXECUTION_AUTHORITY = false · EXECUTION_PERMISSION = false
gateSwissAMLA regulatory determination domain
AUTHORITY BOUNDARY

SWISS AML STATE IS NOT SUPERVISORY AUTHORITY.

CAN

  • deterministically evaluate encoded regulatory conditions
  • bind determinations to source, scope, time and input state
  • surface missing, expired or conflicting regulatory dependencies
  • produce attributable evidence for the concrete determination

CANNOT

  • replace a regulator, supervisor, court or competent institution
  • create legal or regulatory authority through score, consensus, AI or administration
  • turn a gate PASS into an Execution Right on its own
  • mint an ExecutionCapabilityToken on its own
REGULATORY STATE

Regulatory determination is evidence. Not regulatory authority.

SOURCE

Authoritative source

The relevant rule must originate outside the system from a legitimate normative or institutional source.

SCOPE

Defined matter

The determination is limited to the encoded subject, entity, transaction or operation under review.

TIME

Point-in-time state

Effective dates, transition periods, expiry and version state remain explicit.

INPUT

Canonical input

A reproducible determination requires a defined canonical input state.

DEPENDENCY

Dependencies

Missing or contradictory dependencies remain visible rather than being converted into invented permission.

EVIDENCE

Bound evidence

The resulting state can be bound to source, input, scope and time for later verification.

RELATED DETERMINATION DOMAINS

Regulatory domains compose. They do not confer authority on one another.

Only scope-relevant determinations become dependencies in Execution Rights resolution. The links shown are not a universally mandatory sequence.

EXECUTION RIGHTS

Five dimensions. Regulatory state can inform them; no gate replaces them.

AAUTHORITY
RRULE
JJURISDICTION
TTIME
DDEPENDENCY
ALL FIVE REQUIRED DIMENSIONS VALID → VALID EXECUTION RIGHT · ANY REQUIRED DIMENSION ABSENT → NO VALID EXECUTION RIGHT → NO CAPABILITY → NO EXECUTION
INVARIANT

A regulatory PASS is a determination. Never a permission by itself.

AUTHORITY → DETERMINATION → EXECUTION RIGHTS → CAPABILITY OR NONE → EXECUTION OR NONE → EVIDENCE

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