Compliance outsourcing for portfolio managers in Geneva

Geneva's independent portfolio managers typically combine an international client base with French as their working language and English as the language of many clients and teams. Peak Compliance takes over the compliance function for these firms: directives, controls, anti-money laundering clarifications, reporting and audit preparation – carried out by one team that works in French, English and German. Your management concentrates on clients and investment decisions; the second line of defence runs reliably in the background.

What Peak Compliance takes over

The scope follows the duties that Swiss law assigns to the compliance function of a licensed portfolio manager. Peak Compliance performs them independently of the business it monitors, as required by Art. 21 para. 3 FinIA:

• Monitoring compliance with FinIA, FinSA and AMLA requirements
• Anti-money laundering unit: clarifications, risk classification, higher-risk relationships and the AML risk analysis
• Sanctions screening at onboarding and throughout the business relationship
• FinSA rules of conduct: client segmentation, suitability, information and documentation
• Drafting and updating internal directives
• Second-line controls in a digital internal control system
• Periodic reporting to executive management and the board
• Audit preparation and attendance at the closing meeting with the audit firm
• Staff training on site, online or by e-learning

Three services complete the picture:

How the engagement works

1. 1

   Analysis

   Peak Compliance reviews your current compliance and risk framework with you, in French or English, and defines the objectives.
2. 2

   Scope

   together you decide which tasks Peak Compliance takes over – the entire function, the anti-money laundering unit or deputy cover.
3. 3

   Proposal

   you receive a proposal setting out scope, services and the monthly pricing.
4. 4

   Agreement

   the outsourcing agreement defines tasks, reporting lines, rights of control and audit rights (Art. 17 FinIO) and can be accepted online.
5. 5

   Onboarding

   Peak Compliance implements processes and directives, with a kick-off on site in Geneva or remotely.
6. ✓

   Ongoing service

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

What shapes compliance work in Geneva

Swiss financial market law applies in the same way in Geneva as in Zurich or Lugano: FINMA grants the licence, and a supervisory organisation carries out ongoing supervision. What differs is the working environment. Peak Compliance takes these points into account in every Geneva mandate:

• French as working language: directives, client documentation, minutes and reports can be kept in French, with English versions for international teams. FINMA provides the licence application form in German, French, Italian and English, and supervisory audit reports are drawn up in an official language of Switzerland (Art. 84 para. 3 FinIO).
• Supervisory organisations in Geneva: of the four supervisory organisations authorised by FINMA (list as at 5 November 2026), OSIF and SO-FIT have their registered office in Geneva; AOOS is based in Zurich and OSFINcontrol in Zug. Peak Compliance works with the supervisory organisation you have chosen. Background is in our article on supervisory organisations.
• International clients: domicile and nationality of clients and beneficial owners are among the criteria for higher-risk relationships, and relationships with foreign politically exposed persons always count as higher risk (Art. 6 para. 3 AMLA). Peak Compliance builds these factors into the risk classification, the AML risk analysis and the sanctions screening. A practical overview is in our guide to AMLA due diligence for portfolio managers.
• Commercial register: firms in Geneva are entered in the cantonal commercial register. A portfolio manager is entered as a financial institution once FINMA has granted the licence (Art. 5 para. 2 FinIA); Peak Compliance includes this step in the licensing timetable.
• Service from Zurich: board meetings, audit closing meetings and training sessions take place in Geneva when personal presence helps; controls, clarifications and reporting run remotely through the digital internal control system.

Legal basis

• Art. 21 FinIA: portfolio managers have an appropriate risk management system and effective internal control; these tasks may be delegated to a qualified external entity (para. 2); the persons performing them are separate from the activities they supervise (para. 3).
• Art. 14 FinIA: tasks are delegated to third parties with the necessary skills, knowledge and experience, who are carefully instructed and supervised.
• Art. 17 FinIO: the institution remains responsible; the agreement sets out powers, sub-delegation, the duty to render account and rights of control.
• Art. 8 AMLA: organisational measures, in particular adequate staff training and checks.
• Art. 84 FinIO: the supervisory organisation verifies compliance with FinIA, AMLA and FinSA on an ongoing basis.

English versions of Swiss federal law are provided for information only; the German, French and Italian texts are authoritative. The legal framework is explained in our knowledge hubs on FinIA and supervision and on anti-money laundering.

Why Peak Compliance

• Focus: Peak Compliance works for independent portfolio managers, managers of collective assets and family offices in Switzerland and Liechtenstein.
• Three languages, one team: French, English and German, with a responsible lead and a deputy for every mandate.
• 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.
• Digital tools: controls and follow-ups are tracked in a fully digital internal control system, which makes remote collaboration with Geneva straightforward.
• Training: AML and compliance training for your staff, in person or online.
• Team: Peak Compliance AG was founded in Zurich in 2024 by Isabelle Ledergerber and Reto Picenoni; see About us.

Further reading: our earlier article on compliance services in Geneva. Prefer French? Read our page on externalisation de la compliance.

Discuss your compliance in Geneva with Peak Compliance: book a free initial consultation via the contact page.

Responsible

Isabelle Ledergerber

Managing Partner, Co-Founder · LinkedIn profile