AMC, L-QIF & Gold ETF: How Should Risk Concentrations Be Assessed?
10% in a single security and 20% with a single issuer: FINMA Circular 2025/2 identifies these thresholds as indicators of potentially unusual risk concentrations in portfolio management and portfolio-related investment advice.
These figures are not rigid investment limits.
For portfolio managers, the more relevant question is often the level at which the concentration actually arises: at the level of the individual security, the issuer or the product structure.
This distinction becomes particularly relevant for AMC, L-QIF and multiple instruments issued by the same issuer.
AMC: Diversification of the Underlying Is Not Issuer Diversification
An Actively Managed Certificate (AMC) may reference a broadly diversified portfolio. From an investor's perspective, however, the structured product itself remains an additional layer of risk.
During the consultation process for the FINMA Circular, it was proposed that AMC should be excluded from the concentration assessment due to the diversification of their underlying assets.
FINMA explicitly rejected this proposal.
Its reasoning is particularly relevant for portfolio managers: an AMC is a structured product. The issuer, rather than the underlying assets, is responsible for repayment. The issuer risk therefore remains even where the underlying portfolio is diversified.
For portfolio monitoring purposes, two levels should therefore be distinguished:
Underlying exposure and issuer exposure.
This becomes particularly relevant where a portfolio holds several AMC issued by the same issuer. Different investment strategies or underlying assets do not change the fact that the exposure to the same issuer may accumulate.
L-QIF: A Fund Structure Does Not Automatically Mean an Exemption
FINMA Circular 2025/2 excludes concentrations arising from collective investment schemes from the 10%/20% indicators where such schemes are subject to regulatory risk diversification requirements.
The Limited Qualified Investor Fund (L-QIF), however, represents a specific case.
In its consultation report, FINMA expressly states that L-QIF do not require FINMA authorisation or approval and are not covered by the corresponding exemption under the Circular.
For portfolio monitoring purposes, this means that a product should not be excluded from the concentration assessment solely because it is structured as a fund.
It is also necessary to consider whether the requirements for the regulatory exemption are actually met.
Bonds: Individual Security versus Issuer Exposure
For bonds, a purely position-based analysis may also be insufficient.
Several bonds issued by the same company may have different:
- ISINs,
- maturities, and
- coupons.
At individual security level, these constitute separate positions. The issuer risk, however, remains concentrated on the same debtor.
During the consultation process, a general exemption for supposedly “safe” bonds was also proposed and rejected by FINMA.
FINMA specifically referred to the continuing issuer and interest-rate risks, which may result in concentration risks where the portfolio is insufficiently diversified.
For portfolio managers, the aggregate exposure to an issuer is therefore relevant in addition to the size of each individual position.
And What About a Gold ETF?
The relevant FINMA documents do not contain a specific rule for gold ETF.
What is established is the general rule: concentrations arising from collective investment schemes are excluded from the 10%/20% indicators where those schemes are subject to regulatory risk diversification requirements.
For a specific gold ETF, the legal and regulatory structure of the product therefore needs to be assessed first.
This should be distinguished from the economic allocation of the overall portfolio.
In its explanatory report, FINMA notes that concentration risks may arise not only from individual securities, but also from concentrations involving the same issuer, asset classes, correlated sectors, countries or currencies.
Product structure and economic exposure are therefore two separate levels of analysis.
What Does This Mean for Portfolio Monitoring?
A simple 10%/20% traffic-light control will not capture every relevant scenario.
From a risk-management perspective, it is worth considering in particular whether:
- single-security and issuer concentrations are assessed separately;
- several instruments from the same issuer are aggregated;
- issuer risk is considered for structured products;
- funds are not automatically excluded from concentration controls; and
- the regulatory classification of specific structures such as an L-QIF is understood.
In Supervisory Communication 03/2026, FINMA also emphasises the importance of early risk identification and robust governance when financial products are used in individual portfolio management.
Conclusion
A portfolio may appear diversified at individual-position level and still be concentrated at another level.
AMC: diversified underlying assets, but remaining issuer risk.
L-QIF: collective investment scheme, but according to FINMA's consultation report not automatically covered by the relevant exemption.
Bonds: different securities may result in exposure to the same issuer.
Gold ETF: the regulatory classification depends on the specific product structure, while the economic gold exposure should be considered separately.
For portfolio managers, the key question is therefore not only:
“How large is the position?”
but also:
“At which level does the actual risk arise – and does our portfolio monitoring capture that level?”
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Status: September 2026. The article is based in particular on FINMA Circular 2025/2 "Conduct Rules under FinSA/FinSO", the related consultation report and explanatory documents, as well as FINMA Supervisory Communication 03/2026.
