Insights

Hundreds of independent asset managers or trustees have recently received or will soon receive a licence from FINMA. One of the most important associated changes is that these institutions must comply with comprehensive reporting or licensing requirements before implementing important entrepreneurial decisions such as the replacement of member of the board of directors or executive board, the change of organisation or the transfer of a significant shareholding. Initial experience shows that there are numerous challenges associated with the new obligations. In this article, the most important elements of the notification and authorisation obligation as well as sticking points for implementation in practice are outlined.

Two key amendments, in particular, will come into effect on 1 January 2023 as part of the AMLA revision: the obligation to verify the details of the beneficial owner and the obligation to update client details at regular intervals.