Compliance outsourcing for portfolio managers in Switzerland

What does compliance outsourcing cover?

Peak Compliance performs the tasks that the law assigns to the compliance function and keeps them independent of front-office activities. You choose from three models:

• Full outsourcing: Peak Compliance provides your outsourced compliance officer and covers the entire compliance part of the second line of defence.
• Partial outsourcing: Peak Compliance takes over selected tasks such as the anti-money laundering unit, regulatory monitoring or periodic controls, while your in-house team focuses on day-to-day business.
• Deputy cover: Peak Compliance keeps the compliance function running during holidays, absences or until a position is filled.

Typical tasks include:

• Acting as compliance officer and advising management and staff
• Anti-money laundering unit: onboarding reviews (KYC), ongoing monitoring, the annual risk analysis and preparation of reports
• Sanctions monitoring and screening
• Policies and templates: drafting, maintenance and documentation
• Regulatory monitoring: early notice of new requirements – from FinSA and AMLA to topics such as crypto-assets – and support with implementation
• Periodic reporting to executive management and the board
• Audit preparation and attendance at the closing meeting with the audit firm
• Staff training, on site or via e-learning (AML and compliance training)

Compliance works hand in hand with risk management and the internal control system, which Peak Compliance covers through risk management outsourcing.

How does the engagement work?

1. 1

   Analysis

   Peak Compliance reviews your current compliance and risk framework with you and defines the objectives.
2. 2

   Requirements

   Based on your input, Peak Compliance proposes solutions that keep you compliant with legal requirements at all times.
3. 3

   Proposal

   You receive a proposal setting out scope, services and a monthly fixed price.
4. 4

   Agreement

   You can accept the outsourcing agreement online. It defines tasks, reporting lines and audit rights.
5. 5

   Onboarding

   Peak Compliance implements the processes on site or remotely, aligned with your organisation.
6. ✓

   Ongoing service

   Peak Compliance delivers the agreed tasks; you focus on clients and portfolio management.

Legal basis

• Art. 21 FinIA: portfolio managers must have adequate risk management and effective internal control that ensures compliance with legal and internal rules. These tasks may be delegated to a qualified external body (para. 2); the persons performing them may not be involved in the activities they monitor (para. 3).
• Art. 14 FinIA: tasks may be delegated to third parties with the necessary skills, knowledge and experience; the institution instructs and monitors them carefully.
• Art. 26 FinIO: principles of risk management and risk tolerance for portfolio managers.
• Art. 41 FinIO: for managers of collective assets, risk management and compliance are separated functionally and hierarchically from operating units.
• Art. 8 AMLA: financial intermediaries take organisational measures, in particular adequate staff training and controls.

English versions of Swiss federal law are provided for information only; the German, French and Italian texts are authoritative.

Roles and scope

• Peak Compliance: takes over the entire second line of defence – compliance function, anti-money laundering unit, controls and reporting.
• Institution: the board and executive management focus on clients and investment decisions (first line) and receive clear, regular reports from Peak Compliance.
• Supervision: portfolio managers under Art. 17 FinIA are supervised on an ongoing basis by a supervisory organisation (SO); managers of collective assets are supervised directly by FINMA.
• Audit firm: performs the regulatory audit. Peak Compliance prepares the documentation and attends the closing meeting.
• Positioning: Peak Compliance runs a function with a defined scope – at a monthly fixed price instead of hourly rates.

For licensing there is a separate service: FINMA and FMA licensing, in particular for portfolio managers and managers of collective assets. Institutions in Liechtenstein can turn to compliance outsourcing Liechtenstein.

Why Peak Compliance

• Focus: Peak Compliance works for independent portfolio managers, managers of collective assets and family offices in Switzerland and Liechtenstein.
• Supervisory experience: mandates with portfolio managers supervised by FINMA and the FMA, cooperation with the supervisory organisations AOOS and OSFINcontrol, and experience with licensing procedures before FINMA and the FMA.
• Team: Peak Compliance AG was founded in Zurich in 2024 by Isabelle Ledergerber (Managing Partner) and Reto Picenoni (Board member); see About us.
• Digital tools: controls and follow-ups are tracked in a fully digital internal control system.
• Insights: Peak Compliance publishes regular articles, for example on compliance outsourcing in Geneva, sanctions and embargoes and the FINMA guidance on AML risk analysis.

Comparing providers? Our guide to choosing a compliance outsourcing provider sets out objective criteria.

Discuss your compliance outsourcing with Peak Compliance: book a free initial consultation or write to us via the contact page.

Responsible

Isabelle Ledergerber

Managing Partner, Co-Founder · LinkedIn profile