Operational Readiness for FINMA Portfolio Managers: Technology, Risk & Compliance

FINMA Authorization Is Only Half the Journey — Operational Readiness Is the Other Half

Under Switzerland’s FinIA and FinSA regulatory framework, obtaining FINMA authorization is only the beginning.
To start managing client assets, portfolio managers must demonstrate full operational readiness, including:

• A functioning technology stack
• Implemented risk management framework
• FinSA-compliant client onboarding
• Data aggregation & reconciliation
• Suitability / appropriateness checks
• Internal controls & compliance monitoring
• Delegation oversight
• Full documentation & auditability
• Security & IT governance

Swiss supervisory organizations (SOs) focus heavily on whether the firm can operate safely, consistently, and with proper controls.

This guide summarizes everything a newly licensed Swiss portfolio manager must implement before onboarding clients.

1. Technology Infrastructure: The Foundation of Swiss Operational Readiness

FINMA and SOs expect firms to use professional-grade tools, not spreadsheets, for:

• Client onboarding
• AML/KYC
• Suitability documentation
• Portfolio management
• Reconciliation
• Risk analysis
• Reporting
• Audit trails
• Data retention

The minimum viable technology stack includes:

• Digital onboarding & AML/KYC
• FinSA client classification workflow
• Portfolio management system (PMS)
• Multi-custodian data integration
• Reconciliation engine
• Risk dashboards
• Suitability/appropriateness engine
• Compliance monitoring system
• Document vault & version control
• Client reporting system
• Fee billing engine

This stack mirrors that of FCA, CSSF, CySEC, DFSA, and EU MiFID jurisdictions — but tailored to Swiss FinSA/FinIA duties.

2. Client Onboarding, AML, and FinSA Suitability

2.1 Digital Client Onboarding

FINMA and SOs expect:

• Verified client identity
• Document collection
• E-signatures
• Audit trails
• Secure storage

2.2 AML/KYC Requirements

Swiss AML law requires:

• KYC/KYB identity checks
• Verification of beneficial owners
• PEP & sanctions screening
• Source of wealth / funds
• Risk scoring
• Ongoing AML monitoring

2.3 Client Classification (FinSA)

Mandatory segmentation:

• Retail
• Professional
• Institutional

2.4 Suitability & Appropriateness Checks

Portfolio managers must demonstrate suitability across:

• Client objectives
• Risk tolerance
• Financial situation
• Knowledge & experience

Why this matters

FINMA & SOs frequently review suitability documentation for completeness and timeliness.

3. Portfolio Management & Data Infrastructure

Portfolio managers must maintain complete and accurate portfolio data.

3.1 PMS (Portfolio Management System) Requirements

• Multi-asset support
• Real-time valuations
• Performance measurement (TWR/MWR)
• Exposure & risk dashboards
• Corporate actions management
• Model portfolios
• Rebalancing tools
• Fee calculations

3.2 Multi-Custodian Data Integration

Most Swiss asset managers use multiple custodians (UBS, Credit Suisse, Julius Baer, Pictet, Vontobel, GKB, others).

Systems must:

• Fetch custodial data
• Normalize formats
• Map identifiers
• Consolidate portfolios

3.3 Reconciliation

FINMA expects automatic reconciliation of:

• Positions
• Transactions
• Cash balances

This reduces operational risk.

4. Risk Management Framework

Although portfolio managers are less risk-heavy than AIFMs or UCITS ManCos, FINMA still requires a documented and functioning risk framework.

Risk monitoring must include:

• Portfolio risk limits
• Concentration limits
• Market/FX risk checks
• Liquidity (if relevant)
• Stress testing (recommended)
• Counterparty risk
• Monitoring for breaches

SOs expect:

• A functioning, real system — not a policy document
• Evidence of risk controls
• Regular risk reporting

Why this matters

SOs will ask for risk reports during inspections.

5. Compliance & Internal Control System (ICS)

Compliance must be active, documented, and ongoing.

Required components:

• Compliance monitoring plan
• Conflicts of interest register
• Best execution policy & evidence
• Complaints register
• Outsourcing register
• Personal account dealing policy
• Gifts & hospitality tracking
• Incident & breach logs
• Regulatory change tracking

Why this matters

FINMA and SOs expect firms to operate with COB (Conduct of Business) discipline comparable to EU frameworks.

6. Governance Expectations Under FinIA

Governance is a major readiness criterion.

Key governance requirements:

• Active board with oversight duties
• Management with sufficient expertise
• Clear segregation of duties
• Minutes of board & committee meetings
• Annual planning calendar
• Documented decision-making
• Outsourcing oversight
• Compliance & risk reporting to management

Why this matters

Weak governance is one of the most common findings in SO inspections.

7. Reporting Requirements

Swiss portfolio managers must prepare:

Financial Reports

• Annual financial statements
• Three-year forecast
• Capital adequacy confirmation

Risk & Compliance Reports

• Annual risk assessment
• Compliance monitoring results

SO Reporting

• Periodic supervisory reports
• Incident notifications

Client Reporting (FinSA)

• Performance reports
• Cost disclosures
• Portfolio statements
• Suitability updates

8. IT Governance & Cybersecurity

FINMA and SOs require firms to maintain proper IT controls.

IT Governance Requirements

• System access controls
• Password policies
• Data encryption
• Backup procedures
• Disaster recovery plan
• Vendor management
• IT outsourcing contracts
• Cyber incident handling plan

Why this matters

Security incidents must be reported to the SO immediately.

9. The Complete Operational Readiness Checklist for Swiss Firms

Client & AML

• Digital onboarding implemented
• AML policies active
• Ongoing monitoring tools
• Suitability/appropriateness workflows

Portfolio & Risk

• PMS deployed
• Multi-custodian aggregation live
• Reconciliation operational
• Risk monitoring active

Compliance

• Compliance monitoring plan operational
• Registers updated
• Best execution oversight
• Outsourcing logs maintained

Governance

• Board meetings & minutes in place
• ICS implemented
• Policies active
• Staff trained

IT & Security

• Cybersecurity controls active
• Data retention policies
• Backup & DR tested

Reporting

• Annual reports
• Risk & compliance reports
• Client reporting template live

Together, these form the core operational readiness package that FINMA and SOs expect.

10. Why Swiss Portfolio Managers Choose Reluna

Reluna provides all critical operational systems in one integrated platform, reducing complexity and improving regulatory alignment.

Reluna includes:

• Digital onboarding & AML/KYC
• FinSA classification
• Suitability & appropriateness checks
• PMS with analytics & exposures
• Multi-custodian data aggregation
• Reconciliation engine
• Client reporting portal (white-labeled)
• Compliance monitoring (ICS)
• Document vault with audit trails
• Governance & registers
• Fee calculation engine
• Full audit-log architecture

Key benefits

• Faster operational readiness
• Lower cost compared to multi-system architectures
• Stronger compliance & auditability for SO inspections
• Seamless integration of all data
• Single source of truth
• Reduces operational risk
• Scales with the business

Reluna provides Swiss managers with a FINMA-ready operational stack from day one.

11. Next Steps

If you are preparing for FINMA authorization — or have recently received it — now is the critical moment to finalize operational readiness.

👉 Request a Reluna demo to see how we support Swiss portfolio managers through full FinIA/FinSA operational launch.