Sanctions, data protection and outsourcing

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The regulatory framework for wealth management also includes international sanctions. Institutions must screen their clients, their counterparties and their transactions against the sanctions adopted by Switzerland, and must take foreign regimes into account where their operations are exposed to them. Part H will examine this field, which has gained considerable importance since 2022.

Data protection forms another component. The federal data protection legislation, revised and in force since 2023, imposes obligations of transparency, security and documentation that come in addition to bank client secrecy.¹ The outsourcing of functions, in particular IT functions, to service providers, some of them established abroad, must comply with FINMA’s requirements and guarantee the confidentiality of client data.²

Notes

Federal Act of 25 September 2020 on Data Protection (FADP; SR 235.1), in force since 1 September 2023; Federal Office of Justice, “Nouveau droit de la protection des données”, bj.admin.ch (accessed September 2026). ↩
FINMA, press release of 5 December 2017, “La FINMA publie la circulaire sur l’outsourcing” (FINMA publishes the circular on outsourcing): Circular 2018/3 “Outsourcing – banks and insurers”, in force on 1 April 2018, applicable to banks, securities dealers and insurance companies; principles based on the institution’s continuing responsibility for outsourced activities; transitional period for banks’ existing outsourcing arrangements extended from two to five years. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

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Sanctions, data protection and outsourcing

Notes

Setting up or expanding in Switzerland?