Insights

On 22 October 2025, the Federal Council opened the consultation procedure on an amendment to the Financial Institutions Act (FinIA). The plan is to introduce two new licence categories – payment institutions and crypto institutions – with the objective of enhancing the attractiveness of Switzerland as an economic and financial centre and improving the integration of innovative financial technologies into the existing financial system. In the context of the proposed FinIA amendments, other financial market laws (FinSA, AMLA, FINMASA, FinMIA) are also to be amended.

Qualified participants, managing directors or board members of banks and other financial institutions that are licensed and supervised by FINMA will remember the forms with the inconspicuous designations B1, B2 and B3.

The FINMA circular on conduct obligations under the Financial Services Act (FinSA) came into force on 1 January 2025, in some cases with a transitional period until 30 June 2025. There is room for interpretation and uncertainty regarding the implementation of many of the provisions of the new circular. We summarise the most important challenges.

Various amendments to the Collective Investment Schemes Ordinance (CISO) came into force on 1 March 2024. Most of the changes relate to the introduction of the new L-QIF, which we have already reported on separately. However, other significant amendments to the CISO have also been made. These also apply to existing institutions that do not manage L-QIFs and affect various aspects such as the management of liquidity risks.

The legal basis for the Limited Qualified Investor Fund (L-QIF) came into force on 1 March 2024 with the amendments to the Collective Investment Schemes Act (CISA) and the Collective Investment Schemes Ordinance (CISO). Based on the Luxembourg RAIF, this is intended to introduce a more flexible fund in Switzerland, as it already exists in various forms in EU countries. The aim is to strengthen the Swiss fund centre and make it more competitive.

The Ordinance on Asset Management within the Framework of a Guardianship or Conservatorship (VBVV) governs the investment and safekeeping of the assets of persons with protective measures. The completely revised VBVV adopted by the Federal Council on 23 August 2023 will enter into force on 1 January 2024.

In the April issue of B2B Magazine, Fabian Schmid and Anael Rosalen shed light on the special features of de minimis portfolio managers and their differences from portfolio managers of collective assets.

Are you looking for a suitable partner for your compliance education and training? You already have an established compliance training concept, but would like to train your employees on selected regulatory topics in cooperation with proven experts? We offer you the planning, organisation and implementation of individual training events tailored to your company for yourself and your employees.

Two key amendments, in particular, will come into effect on 1 January 2023 as part of the AMLA revision: the obligation to verify the details of the beneficial owner and the obligation to update client details at regular intervals.