Legal · Compliance Framework v1.0
Compliance
1. Regulatory basis
WIRELY operates as a regulated financial intermediary in Switzerland. We adhere to the Swiss Anti-Money Laundering Act (AMLA/GwG), the Financial Services Act (FinSA), the revised Federal Act on Data Protection (nFADP), and FINMA circulars — specifically FINMA Circular 2016/7 (identification of the contracting party) and FINMA Circular 2020/3 (outsourcing and digital onboarding).
WIRELY maintains a dual identification model:
- In-person identification and documentation at our registered office
- Digital identification via Didit, embedded natively in the SendFund App
2. Identity verification
2.1 In-person identification (office visit)
Clients who visit our registered office at Wartstr 22, 8400 Winterthur undergo physical identity verification in accordance with AMLA Art. 3: presentation of a valid government-issued ID, in-person visual verification against the client's appearance, a document authenticity check, and a certified, signed copy of the ID. No biometric data is stored from in-person visits beyond the scanned ID copy.
2.2 Digital identification via Didit
For remote onboarding, Didit is embedded into the SendFund App as our delegated identity verification provider under FINMA outsourcing rules.
| Step | Action | Didit's role |
|---|---|---|
| 1 | User opens the SendFund App | Didit SDK initializes |
| 2 | Document capture | Didit scans MRZ and photo |
| 3 | Liveness detection | Didit checks the depicted person is physically present (video selfie + movement) |
| 4 | Chip reading (NFC) | Didit validates e-passport / e-ID chip |
| 5 | OTP | OTP verification via SMS or WhatsApp is initiated |
| 6 | Result returned | Didit returns Verified / Unverified + confidence score |
WIRELY does not store raw biometric data (selfie videos) — Didit returns a cryptographic proof of verification (hash + signed attestation). The client approves their ID data and verification status explicitly within the App before submission. Didit's identity verification solution complies with FINMA Circular 2016/7 (online identification), including liveness detection, document authenticity checks, and age verification. Didit maintains ISO 27001 certification and undergoes annual external audits, and provides an annual ISAE 3402 / SOC 1 Type II report.
3. Age verification
WIRELY does not onboard any individual under the age of 18 — this applies equally to physical office visits and digital onboarding. For in-person visits, a compliance officer reads the date of birth directly from the physical ID; if a client appears underage but claims otherwise, a second officer cross-checks the ID. For digital onboarding, Didit extracts the date of birth from the ID document or e-ID chip and returns a pass/fail age check — the App enforces a hard block if the result is fail. Every age verification event is logged with a timestamp, method, and result.
4. Data protection
WIRELY complies with the revised nFADP and, where applicable, GDPR for cross-border clients. See our full Privacy Policy for details. Key principles:
| Data minimization | Only ID attributes (name, date of birth, address, nationality, ID number) are processed. |
| Purpose limitation | Data used only for AML/KYC and regulatory reporting. |
| Storage limitation | 10 years after contract end (AMLA Art. 21), then deleted or anonymized. |
| Transparency | Clients accept a Privacy Notice before verification. |
| Biometric data | Didit processes biometrics (facial liveness) but does not return raw biometric data to WIRELY — only a verification attestation. |
| Data sovereignty | All data stored in Switzerland (Tier IV data centers). |
Client rights under the nFADP include access, rectification, erasure (subject to AML retention obligations), and restriction. To exercise these rights, contact info@sendfund.app.
5. Regulatory status and certifications
| Status | Licensed financial intermediary (Financial Intermediary License) |
| UID (Tax ID) | CHE-497.268.005 (active) |
| Supervisory authority | SRO ARIF |
| Registered address | Wartstr 22, 8400 Winterthur |
Internal certifications:
- ISO 27001:2022 (Information security management — entire KYC process)
- ISO 27701 (Privacy information management)
- Swiss Banking Standards (self-assessment for outsourced digital onboarding)
6. Questions
For compliance-related inquiries, reach us at info@sendfund.app or via our contact page.
