Outsourced compliance officer for Swiss portfolio managers

Every licensed portfolio manager needs someone who holds the compliance role: a person who knows the rules, checks that they are applied and reports clearly to management and the board. Many independent firms entrust this role to an outsourced compliance officer. Peak Compliance provides that officer – with a responsible lead, a deputy and a team behind them – so that your compliance function is staffed, documented and ready for audit at all times.

What does an outsourced compliance officer do?

The outsourced compliance officer performs the tasks of the second line of defence and keeps them separate from client business and investment decisions (Art. 21 para. 3 FinIA). With Peak Compliance, the role typically covers:

• Regulatory monitoring: following changes in FinIA, FinSA, AMLA and FINMA practice and translating them into concrete measures.
• Directives: drafting and updating internal directives on compliance, anti-money laundering, FinSA rules of conduct and sanctions.
• Anti-money laundering unit: advising line managers and executive management, preparing the AML directives and planning and monitoring AML training (Art. 24 AMLO-FINMA); where required, also monitoring, additional clarifications and the AML risk analysis (Art. 25 AMLO-FINMA).
• Client files: reviewing onboarding files, higher-risk relationships and periodic reviews.
• Controls: second-line controls according to the control plan, with evidence in the digital internal control system.
• Reporting: periodic reports to executive management and the board, including the annual compliance report.
• Audits and supervision: preparing audits, supporting the dialogue with the supervisory organisation and preparing notifications of changes.
• Training: staff training on site, online or by e-learning.

When an external compliance officer is a good fit

An outsourced compliance officer suits firms that want expertise and continuity in the role without building a full internal team. Typical situations:

• New licence: the FINMA application describes the compliance function; an external officer can be named from the start.
• Growth: client numbers, products or markets grow faster than the internal team.
• Change of staff: the internal compliance officer leaves, and the function needs to stay in place without interruption.
• Deputy cover: an internal compliance officer needs a qualified deputy for absences.
• Findings from audits: the audit firm or the supervisory organisation asks for a stronger second line.

For smaller portfolio managers, the law sets out a proportionate approach. Risk management and internal control may be combined with revenue-generating activities if the firm has five or fewer full-time positions or annual gross earnings of less than CHF 2 million and a business model without high risks (Art. 26 para. 2 FinIO). The AML unit of such firms may concentrate on the core tasks of Art. 24 AMLO-FINMA (Art. 75 AMLO-FINMA). An external compliance officer gives these firms independent expertise at a size that fits.

How the mandate is set up

1. 1

   Analysis

   Peak Compliance reviews your organisation, business model, client base and existing directives with you.
2. 2

   Scope

   you decide whether Peak Compliance takes over the entire compliance role, the anti-money laundering unit or deputy cover.
3. 3

   Proposal

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

   Agreement

   the agreement defines tasks, powers, sub-delegation, the duty to render account and your rights of control (Art. 17 para. 2 FinIO); your organisational regulations reflect the delegated tasks (Art. 17 para. 3 FinIO).
5. 5

   Handover

   Peak Compliance takes over documents and open items, sets up the control plan and introduces the named lead and deputy to your team.
6. ✓

   Ongoing role

   the outsourced compliance officer performs the agreed tasks and reports regularly to management and the board.

What qualifies an external compliance officer

The law requires delegation to a third party with the necessary skills, knowledge and experience (Art. 14 para. 1 FinIA). In practice, four points matter:

• Expertise: practical knowledge of FinIA, FinSA and AMLA and of how supervisory organisations and audit firms review them.
• Independence: the officer is separate from the activities they supervise (Art. 21 para. 3 FinIA).
• Access and control rights: full access to client files and processes, and documentation that the audit firm, the supervisory organisation and FINMA can review (Art. 17 para. 4 FinIO).
• Continuity: a named deputy, so that deadlines, audits and supervisory enquiries are covered at all times.

Our guide to choosing a compliance outsourcing provider sets out further objective criteria.

Outsourced compliance officer in Liechtenstein

In Liechtenstein, the Due Diligence Ordinance allows the tasks of the due diligence officer and the investigating officer to be entrusted to suitably qualified external persons or specialist bodies; the appointment is notified to the FMA (Art. 36 SPV). Peak Compliance takes over these tasks for FMA-supervised asset management companies through compliance outsourcing Liechtenstein.

Legal basis

• Art. 21 FinIA: risk management and internal control; delegation to a qualified external entity (para. 2); independence from the activities supervised (para. 3).
• Art. 14 FinIA: delegation to qualified third parties who are carefully instructed and supervised.
• Arts. 16 and 17 FinIO: delegable tasks, responsibility of the institution and content of the agreement.
• Art. 26 FinIO: risk management principles, risk tolerance and the proportionate approach for smaller firms.
• Arts. 24, 25 and 75 AMLO-FINMA (German): tasks of the anti-money laundering unit and designation of external specialists.
• Art. 8 AMLA: organisational measures, staff training and checks.

English versions of Swiss federal law are provided for information only; the German, French and Italian texts are authoritative. Background on anti-money laundering duties is in our AML knowledge hub.

Why Peak Compliance

• The full function: Peak Compliance provides the compliance officer as part of compliance outsourcing and, on request, risk management outsourcing with a digital internal control system.
• 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.
• New firms: support with the portfolio manager licence and an outsourced compliance officer from day one.
• Across Switzerland: from Zurich, in Vaduz and for firms in French-speaking Switzerland, for example through compliance outsourcing in Geneva.
• Training: AML and compliance training for your staff.
• Practical guidance: for example on the internal control system for portfolio managers and on compliance planning 2027. More about the team: About us.

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

Responsible

Isabelle Ledergerber

Managing Partner, Co-Founder · LinkedIn profile