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Maclear's Annual Inspections by the PolyReg Self-Regulatory Organization: Far Beyond Anti-Money Laundering

Switzerland is recognized worldwide for one of the most robust and well-supervised financial systems on the planet. In line with other European countries, it boasts highly qualified professionals and stringent regulations that serve as a global benchmark. It was precisely this environment that led Maclear to establish its headquarters here and develop its innovative crowdlending proposition. Regulatory requirements are demanding, but the benefit is undeniable: both borrowers and investors enjoy maximum security and protection of their rights and assets.

The Swiss Financial Market Supervisory Authority (FINMA) sets the overarching framework of applicable legislation and authorizes self-regulatory organizations (SROs) to establish more specific rules and ensure compliance as a condition of membership. The SRO to which Maclear belongs is PolyReg, which closely monitors its members' activities. The admission process is thorough, and whenever irregularities are suspected on the part of any member, the organization has the right to conduct extraordinary audits in addition to the regular scheduled ones.

In This Article

PolyReg Policies

Excerpt from PolyReg SRO official regulations document outlining the purpose, scope of application, and guidelines for financial intermediaries regarding anti-money laundering and terrorist financing compliance under Switzerland's AMLA.

Founded in Zurich in 1999, the PolyReg SRO enforces the provisions of Switzerland's Anti-Money Laundering Act (AMLA), which establishes a rigorous regulatory framework for the financial sector. In this context, crowdlending platforms are required to ensure full compliance with all legal and regulatory obligations while protecting the interests of investors.

SRO oversight aims to create a safe environment for investors by imposing consistent operational, organizational, and risk management standards across its members. This includes the obligation for financial intermediaries to:

  • Identify and verify the identity of all borrowers and beneficial owners;
  • Monitor relationships and transactions, detecting suspicious or unusual activity at an early stage;
  • Maintain internal control structures, including dedicated departments, responsible officers, and reporting channels;
  • Record events transparently, including notifications to Switzerland's Money Laundering Reporting Office (MROS);
  • Implement asset protection measures, including protocols for responding to irregularities.

For crowdlending platforms specifically, the SRO imposes additional safeguards to protect investor capital. Members must have in place:

  • Clear procedures for onboarding borrowers, including identity verification and credit assessment;
  • Systems for monitoring the flow of funds and detecting high-risk transactions or sudden changes in borrower behavior;
  • Transparent communication with investors regarding the management and security of their funds;
  • Annual audits and, where necessary, unannounced inspections to verify compliance with internal guidelines and AMLA obligations.

By combining risk-based monitoring, mandatory internal controls, and extraordinary audits, PolyReg helps create a trustworthy ecosystem in which investors on crowdlending platforms can participate with confidence, knowing their investments are supervised in accordance with Swiss regulatory standards.

The PolyReg Admission Process

Before a financial intermediary can operate under PolyReg SRO supervision, it must pass through a rigorous, multi-stage admission process designed to ensure that only serious, qualified, and financially sound operators enter the Swiss market. Maclear's approval illustrates the exacting criteria applied to protect investors and preserve the integrity of the system.

Financial Soundness Review

The SRO assesses the financial stability of the intermediary to confirm that it has sufficient capital to operate safely and meet its obligations. This step protects investors from platforms that may overextend themselves or mismanage funds. The application process is deliberately detailed and, once complete documentation has been submitted, a decision typically takes between 2 and 8 weeks.

Reputation and Integrity Check

Directors, shareholders, and other key individuals are evaluated for legal compliance, any prior regulatory issues, and professional reputation. This vetting ensures that those responsible for managing investor funds have a clean track record and are not engaged in fraudulent or negligent activities.

Management Competency Assessment

The experience, expertise, and organizational capabilities of the management team are reviewed to confirm that the company is equipped to implement sound governance, risk management, and anti-money laundering procedures.

Through this layered selection process, the SRO screens out high-risk operators before they can gain membership. Only platforms that demonstrate financial soundness, regulatory integrity, and operational competence — such as Maclear — are approved and listed on the organization's public register, ensuring that investors interact only with trusted intermediaries in a safe and transparent environment.

Organizational Structure

The process requires detailed documentation covering the company's governance bodies, executive management, employees, and agents.

Abuse Prevention

Extraordinary inspections can be initiated in response to suspicious activity, irregularities, or violations identified during routine audits. The SRO also has structured enforcement mechanisms: upon identifying deficiencies, it issues corrective instructions to members. Repeated or serious non-compliance can result in fines, remedial measures, or even expulsion from membership.

Comprehensive Investor Protection

Swiss SROs are notably more rigorous than their counterparts in other parts of the world — a defining feature of European regulatory systems. Membership in PolyReg establishes a solid investor protection framework at every stage of the relationship with crowdlending platforms. For Maclear, this means investors are protected not only against unlawful activity, but also against operational and financial risks that often go unaddressed in less strictly regulated markets.

Legal Integrity of Platform Operations

All members, including Maclear, undergo a detailed review of their corporate governance, internal controls, and business practices. Equally important is the proper segregation of client accounts and assets. The SRO requires member platforms to maintain separate accounts for client funds in accordance with the Swiss Code of Obligations, preventing any commingling of investor money with the platform's operational finances. This structural safeguard protects investors even in the unlikely event of a financial or operational failure by the platform itself.

A Global Benchmark for Regulatory Rigor

In jurisdictions with minimal oversight, investors are exposed to systemic risks. Without independent audits, segregation requirements, or comprehensive legal review, lenders may face opaque fee structures, unverified financial statements, or even outright fraud.

Maclear demonstrates in practice that investor protection is not an afterthought — it is embedded in every aspect of its operations, offering Swiss and European investors a platform they can trust with confidence.

How Maclear Implements Internal Controls and Compliance

Maclear's commitment to investor security does not end with regulatory approval or PolyReg membership: it is deeply woven into the operational fabric of the company through a sophisticated network of internal controls and compliance functions. SRO oversight goes beyond surface-level checks — it examines the mechanisms governing day-to-day operations to ensure the continuous upholding of the highest standards of financial integrity.

At the heart of our operations are clearly defined AML roles, carried out by experienced compliance officers whose sole responsibility is to oversee anti-money laundering procedures and investor protection. These professionals ensure that every borrower is properly verified, that beneficial owners are transparently identified, and that high-risk activities are flagged and reviewed in accordance with risk-based protocols. All staff involved in AML-related tasks — from analysts monitoring transactions to executives approving client onboarding — are documented and verified.

PolyReg requires that internal controls be demonstrably effective. To meet this standard, we have implemented rigorous reporting channels, automated transaction monitoring systems, and internal audits that complement external inspections. Training is continuous and mandatory, ensuring that our team remains up to date on regulatory requirements, emerging risks, and operational best practices.

Agents or third parties acting on our behalf are held to the same standards, with all documentation maintained meticulously to allow for immediate review during PolyReg audits.

Full Transparency From Maclear

Transparency starts with clear and accessible reporting. Maclear uses a credit risk rating system ranging from AAA to D, modeled on the frameworks of the world's three leading rating agencies, with full fund flow tracking. Furthermore, since loans are disbursed incrementally rather than all at once, investors themselves can monitor borrower payment performance, further mitigating risk.

In the event of a default — beyond the single default that has occurred in Maclear's history — there is a dedicated reserve fund to cover such losses in the short term, and real collateral to cover any remaining losses following legal proceedings over the longer term. For each credit stage, detailed statistics are made available and updated automatically.

Risk Mitigation

Maclear encourages diversification strategies, guiding investors to spread their capital across multiple borrowers and projects in order to reduce concentration risk. The platform provides tools to monitor portfolio exposure and sends alerts in the event of unusual or high-risk activity by borrowers.

We also maintain open communication channels between investors and our compliance and support teams. Questions about borrower profiles, transaction processes, or asset protection measures are addressed promptly, ensuring that investors fully understand the safeguards available to them. This approach not only meets but exceeds the rigorous operational and governance standards set and enforced by PolyReg.

Bar chart showing the growth of Swiss P2P personal loan volume in CHF millions from 2014 to 2024, peaking at CHF 607 million in 2021, according to the Hochschule Luzern Crowdfunding Monitor 2025.

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