The independent or external asset manager is a Swiss speciality with a long tradition. It makes investment decisions for its clients but does not hold their assets: they sit with a custodian bank, and the manager acts under a limited management power of attorney. Many family offices work with such managers or are organised that way themselves.
Licence under FinIA
The Financial Institutions Act (FinIA), in force since 1 January 2020, made portfolio managers and trustees subject to licensing. They need a FINMA licence tied to requirements on organisation, guarantee of irreproachable business conduct, capital and risk management. The transitional period for existing managers ended at the end of 2022.
Supervisory organisation instead of SRO
Ongoing supervision is carried out not by FINMA itself but by a supervisory organisation (SO) it has authorised, which also monitors compliance with the Anti-Money Laundering Act. That distinguishes asset managers from other financial intermediaries that join a self-regulatory organisation. Groups combining both models, such as asset management and fiduciary services, must separate responsibilities cleanly.
AML and conduct duties
Asset managers are financial intermediaries under the Anti-Money Laundering Act: identifying the contracting party, establishing beneficial owners, risk classification, additional enquiries, documentation, duty to report. In addition there are the conduct rules of the Financial Services Act (FinSA), on information, appropriateness and suitability and documentation. The custodian bank carries out its own due diligence; it does not replace the manager’s.
Daily operations
A typical manager works with several custodian banks, often for the same family. The familiar tasks follow: consolidating positions and transactions from different sources, reconciling, valuing, reporting and invoicing. On top come powers of attorney, profiles and documents per mandate. In small firms this work often takes more time than investing itself.
Since the 2026 AMLA revision
The revision in force since October 2026 extends the circle of obliged persons to certain advisory activities. For licensed asset managers the principle does not change, but those who also advise, for example on setting up structures, should check whether that activity is now covered. FINMA-supervised entities that were acting as advisers on 1 October 2026 must notify FINMA by 1 December 2026.