The operational base for independent wealth managers

Wealth managers setting up on their own usually look for systems first. That is the second step. The first is asking what has to be demonstrable in the end, because that determines what the systems must deliver.

FinIA prescribes no product. It requires an outcome: appropriate corporate governance rules, effective internal controls and risk management that ensures compliance with legal and internal rules. Reverse that order and start with software selection, and you buy features while hoping the duties are covered.

The short version

• The law names outcomes, not systems: Art. 9 FinIA requires appropriate governance rules and effective internal controls, Art. 21 FinIA requires adequately resourced risk management.
• Records must be kept for at least ten years after the business relationship ends (Art. 7 para. 3 AMLA).
• Ongoing supervision sits with a supervisory organisation licensed by FINMA (Art. 61 FinIA), not with FINMA itself.
• Under Art. 21 FinIA, anyone performing risk management or internal control duties must not be involved in the activities they monitor. In a small firm this is the hardest requirement to meet.

What comes before choosing systems

Art. 9 FinIA requires a financial institution to establish appropriate corporate governance rules and to be organised so that it can meet its legal obligations. It identifies, measures, manages and monitors its risks, including legal and reputational risks, and ensures effective internal controls.

Art. 21 FinIA is more specific. Wealth managers need adequately resourced risk management and effective internal control that, among other things, ensures compliance with legal and internal rules. The second part of the provision is frequently overlooked when a firm is being built: people performing risk management or internal control duties must not be involved in the activities they monitor. In a three-person firm that is an organisational question, not a technical one.

Art. 11 FinIA adds the guarantee of proper business conduct, which both the institution and the people entrusted with its administration and management must provide.

Further reading: Becoming an independent asset manager: the path to FINMA authorisation

The custodian: the access everything runs through

A wealth manager does not hold client assets. Under Art. 17 FinIA, it disposes of assets held at a custodian bank on the basis of a mandate. That relationship is therefore the one infrastructure decision the manager does not make alone, because the bank has to accept the firm as well.

What matters in the selection: access and minimum volumes, the investable universe, the quality of the data interfaces for positions and transactions, the terms for custody and trading, and how quickly an account opening actually completes. The last point is rarely weighted in comparisons and is the one felt most in daily work.

Swiss custody fees are only partly comparable, because they combine safekeeping, transaction costs, currency spreads and product costs. A comparison that looks only at the stated custody fee falls short.

Further reading: AI tools in financial advice: gaining efficiency without losing proximity

Portfolio administration and reporting

Portfolio administration is where positions, transactions and valuations come together. It provides the basis for monitoring portfolios, for checking agreed investment guidelines and for reporting to clients.

Two requirements decide whether a system is fit for purpose. First, data quality at the custodian interface, because a report is only as sound as the position data behind it. Second, traceability: when a client asks in two years why a position was sold at the time, the answer has to come from the system rather than from memory.

Client records and access

A client relationship system keeps master data, agreements, contact history and documents in one place. Its value lies less in sales support than in reconstructability: who agreed what and when is the same question in an audit as it is in a client conversation.

Client portals give clients sight of holdings, valuations and costs. The scope varies widely, from a plain document store to a running view of total wealth across several custodians.

Further reading: How to become a financial advisor in Switzerland

Documentation, retention and data protection

Art. 7 AMLA requires records on transactions and clarifications to be prepared so that qualified third parties can form a reliable judgement on transactions and business relationships and on compliance with the act. Since 1 January 2023 there is an additional duty to review records periodically for currency and update them where needed, with frequency and scope depending on the risk the counterparty represents.

The retention period under Art. 7 para. 3 AMLA is at least ten years from the end of the business relationship or the completion of the transaction. For system selection this means access has to outlast the termination of a software contract. A firm that holds documents solely inside a rented system has not answered that question.

The Data Protection Act (DSG, SR 235.1) applies in parallel; its revised version entered into force on 1 September 2023. Client data in a discretionary mandate is as a rule particularly sensitive, which sets requirements for processing, storage location and access rights.

Further reading: Target group specialization for financial advisors: more sales, fewer customers

Who reviews the result

Ongoing supervision of wealth managers is not carried out by FINMA itself but by a supervisory organisation it has licensed (Art. 61 FinIA). Art. 62 FinIA adds a review by an audit firm where the supervisory organisation does not carry it out itself; that cycle may be extended to a maximum of four years.

For infrastructure this creates a practical requirement that is rarely raised during selection: can the systems show that internal rules were followed, without someone assembling the evidence by hand?

Frequently Asked Questions on the Operational Base

Which systems does Swiss law prescribe for wealth managers?

None. FinIA names no product at all. It requires an outcome: appropriate corporate governance rules, effective internal controls and risk management that ensures compliance with the applicable rules (Art. 9 and Art. 21 FinIA). The institution decides for itself which systems achieve that, but must be able to demonstrate the result to its supervisory organisation.

How long do records have to be kept?

At least ten years after the business relationship ends or the transaction is completed (Art. 7 para. 3 AMLA). The records must allow qualified third parties to form a reliable judgement on transactions and business relationships and on compliance with the Act.

Do these obligations also apply to client advisers without a FinIA licence?

Only in part. Anyone who qualifies as a wealth manager under Art. 17 para. 1 FinIA requires authorisation from FINMA under Art. 5 FinIA. Client advisers of Swiss financial service providers that are not prudentially supervised, and client advisers of foreign providers, are instead subject to registration in the register of advisers under Art. 28 and 29 FinSA. The operational requirements differ accordingly. Whether an activity requires authorisation is for FINMA to assess on a case-by-case basis.

Who checks whether the infrastructure is sufficient?

Ongoing supervision is carried out by a supervisory organisation licensed by FINMA (Art. 61 FinIA). An audit firm reviews the institution in addition; the supervisory organisation may extend the audit cycle to a maximum of four years (Art. 62 FinIA).

Building it yourself or working with a partner

Both are viable, and the decision depends less on licence costs than on where your own time goes. Building it yourself means contracts with several providers, interfaces between them, and responsibility for the chain producing the evidence at the end.

Everon provides this base as a partner. We have brought the components described here together into one infrastructure used to open accounts, run portfolios and produce reports. Regulatory responsibility stays with the licensed institution; a partner does not take it over, it makes it demonstrable. Talk to us.

Last reviewed: August 2026. Sources: FinIA (SR 954.1), AMLA (SR 955.0), FinSA (SR 950.1), DSG (SR 235.1).