VSB — Agreement on the Swiss Banks' Code of Conduct with Regard to the Exercise of Due Diligence

The Agreement on the Swiss Banks' Code of Conduct with Regard to the Exercise of Due Diligence (VSB) is a private-law self-regulatory framework of the Swiss Bankers Association (SBVg), recognized by FINMA as a regulatory minimum standard. It defines minimum due diligence standards for Swiss banks, particularly regarding client identification and beneficial owner determination.

• Client identification: Identification of natural and legal persons
• Beneficial owner determination: Form A (beneficial owner), Form K (controlling persons for operationally active legal entities), Form S (foundations and trusts), Form T (trusts and fiduciary relationships)
• Prohibited actions: Prohibition of active assistance in capital flight, tax evasion, and circumvention of reporting obligations (tax evasion prohibition since VSB 08)
• Sanction mechanism: Supervisory Commission (Aufsichtskommission) for violations

The VSB was first introduced in 1977 in response to international pressure following the Chiasso scandal (1977, Schweizerische Kreditanstalt / Swiss Credit Bank) in which criminal funds flowed through Swiss banks on a large scale — the SBVg responded with voluntary self-regulation.

The VSB has been regularly revised and tightened: 1982 (VSB 82), 1987 (VSB 87), 1992 (VSB 92), 1998 (VSB 98, synchronization with GwG), 2003 (VSB 03), 2008 (VSB 08), 2016 (VSB 16), and 2020 (VSB 20). VSB 20 is aligned with FIDLEG and revised GwG provisions. The validity period of VSB 20 expired at the end of 2025; the successor version VSB 25 was prepared by the SBVg.

The VSB applies to all member banks of the Swiss Bankers Association as well as banks that have concluded a corresponding agreement with FINMA. Covered are:

• All banks domiciled in Switzerland
• Swiss branches of foreign banks
• Securities dealers that have signed the VSB

• Identification obligation: Written identification of contracting party before or upon opening of the business relationship
• Form A: Declaration of beneficial owner for private accounts/custody accounts
• Form K: Disclosure of controlling persons for operationally active legal entities and partnerships
• Form S: Special form for foundations and trusts
• Form T: Special form for trusts and fiduciary relationships
• Form R: Special form for life insurance policies with surrender value
• Prohibition of assistance in prohibited actions: No active support for capital flight, tax evasion (since VSB 08), and circumvention of reporting obligations
• Supervisory Commission: Own sanction mechanism with fines up to CHF 10 million

"CDB — Agreement on the Swiss Banks Code of Conduct with Regard to Due Diligence" was classified under theme "Jurisdiktion". Correct is "AML-KYC". National laws and authorities are classified by subject matter, not as Jurisdiction. Country profiles are classified as Jurisdiction.

3 corrections:
- VSB versions in key_dates use generic year-start dates instead of actual effective dates
- VSB is not a joint framework of SBVg and FINMA
- Inconsistent bank name DE/EN: Schweizerische Kreditanstalt vs. Credit Suisse
1 update:
- VSB 20 validity: 'valid until end of 2025' is outdated
5 clarifications.
2 notes.