Compliance Planning 2027: Checklist for Swiss Portfolio Managers

What it is about

The end of the year is the right time to plan the 2027 compliance year. An annual plan brings three things together: regulatory changes with their deadlines, recurring duties and the dates of the supervisory audit. Spreading these points across the quarters early lets you implement them calmly and completely – and shows executive management and the board at any time where the compliance function stands.

This article summarises the 2027 priorities for portfolio managers and managers of collective assets and sets out an annual plan you can adopt directly. The legal framework is in our knowledge hub on FinIA and supervision.

What applies in 2027 – the priorities

Anti-money laundering law: AMLA revision and AMLO-FINMA

• Revised AMLA and transparency register: the revised Anti-Money Laundering Act and the Federal Act on the Transparency of Legal Persons have applied since 1 October 2026. The details are summarised in our article on the partial revision of the AMLO-FINMA, the AMLA revision and the transparency register.
• Partially revised AMLO-FINMA: it is expected to enter into force on 1 January 2027. Directives, forms and controls are aligned with the final wording.
• Transparency register: depending on the legal form, the transitional periods for reporting beneficial owners run into early 2027. Our article on the transparency register and EasyGov shows how the filing works.

AML risk analysis as a management tool

With Supervisory Notice 04/2026, FINMA underlines that the risk analysis reflects the institution's actual risks: with a defined risk tolerance, inherent risks and effective measures. In 2027, portfolio managers extend the analysis to sanctions and proliferation financing and take the current FATF country lists into account.

FinSA audit priorities of the supervisory organisations

Since 2026, the supervisory organisations have been reviewing in more depth whether client segmentation, suitability, information duties, documentation and conflicts of interest are applied in practice. The details are in our article on the 2026 FinSA audit priorities.

Recurring duties

• Periodic review of business relationships under Art. 7 para. 1bis AMLA, risk-based and documented.
• Staff training on money laundering and sanctions, for example with an AML training course.
• Client adviser register: client advisers renew their registration after 24 months at the latest (Art. 41 para. 2 FinSO); the client adviser register training offers the refresher for this.
• Internal control system: control plan, execution of controls and open items, for example as part of risk management outsourcing.

Step by step: the annual plan by quarter

1. 1

   December 2026 – stocktaking

   record changes and recurring duties, assign owners, have the plan adopted by executive management.
2. 2

   Q1 2027 – anti-money laundering

   align directives with the partially revised AMLO-FINMA, update the risk analysis, complete the filing with the transparency register.
3. 3

   Q2 2027 – FinSA and products

   check client segmentation, suitability and product selection by sample, prepare for the audit by the supervisory organisation.
4. 4

   Q3 2027 – training and controls

   hold training sessions, check client adviser register deadlines, complete periodic reviews.
5. ✓

   Q4 2027 – report and outlook

   annual compliance and risk management report to executive management and the board, planning for 2028.

Checklist for the start of the year

• 2027 annual plan with quarterly goals and owners adopted
• AML directives aligned with the 2027 AMLO-FINMA
• AML risk analysis updated to cover sanctions and proliferation financing
• Beneficial owners reported to the transparency register
• Dates of the supervisory audit and the audit firm in the calendar
• 2027 training plan and client adviser register deadlines recorded
• Control plan of the internal control system for 2027 approved
• Reporting dates to executive management and the board fixed

How Peak Compliance supports you

Peak Compliance draws up the compliance plan with you, implements the 2027 changes and reports continuously to executive management and the board – as an outsourced function through compliance outsourcing. For a first conversation, reach us via the contact page.