Operational Resilience / Outsourcing in Switzerland
Operational Resilience / Outsourcing regulatory updates from Switzerland.
We track 22 Operational Resilience / Outsourcing updates from Switzerland regulators, published by FINMA. The archive covers 11 news items, 5 guidance notes and 5 regulatory notices. Most recent update: September 2026. Coverage runs from 2025 to 2026.
This is a keynote address from FINMA's CEO at the Small Bank Symposium outlining supervisory philosophy and practice. It provides substantive regulatory signals on how proportionality is applied in practice (e.g., small banks regime, RWA exemptions, differential inspection frequencies, AI and outsourcing...
The Swiss Financial Market Supervisory Authority FINMA supports the consultation drafts presented by the Federal Council for the implementation, within the Banking Act and the Liquidity Ordinance, of the measures set out in the Federal Council’s “too big to fail” report and the PInC report on the CS crisis. These are…
The Swiss Financial Market Supervisory Authority FINMA has today published its guidance on quantum computing. The guidance presents the results of a survey on the opportunities and risks posed by quantum computers and discusses possible measures to mitigate the cyber risk posed by powerful quantum computers.
The Swiss Financial Market Supervisory Authority FINMA welcomes the announcement made today by the Federal Department of Finance (FDF) regarding the establishment of a working group to optimise financial market regulation in Switzerland. FINMA will support this group with its experience and expertise.
Why this matters
FINMA announces support for a regulatory optimization working group. The content discusses supervisory efficiency improvements, fund authorization processes, and insurance intermediary licensing.
FINMA Chair's speech on SupTech and AI's transformative role in financial supervision. Addresses AI-driven supervisory modernization across banking, securities, and crypto markets. Discusses efficiency gains, systemic risks from concentrated AI models, governance challenges, and fraud detection.
In its new Guidance, the Swiss Financial Market Supervisory Authority FINMA explains the risk patterns it is increasingly observing in relation to the use of products in individual portfolio management in the context of escalation cases. The Guidance recalls the rules that institutions must follow when products are…
FINMA's annual media conference outlining 2025 supervisory priorities. Covers resilience and capital adequacy across banks and insurers, operational risks from outsourcing and cyber threats, client protection in asset management, and AML/sanctions compliance.
A survey of banks conducted by the Swiss Financial Market Supervisory Authority FINMA shows that there is a need for action in addressing digital fraud risks, particularly in the areas of operational risk management and preventing money laundering. FINMA published its findings today in a new guidance.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 8 der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
AI Analysis
On February 23, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 8 of the Ukraine Sanctions Ordinance (SR 946.231.176.72), with changes taking effect on February 24, 2026 at 11:00 PM UTC. This represents the latest iteration of Switzerland's Russia sanctions regime, requiring financial intermediaries to immediately implement new prohibitions, freeze assets of designated persons, and report affected business relationships to SECO—with mandatory additional due diligence under anti-money laundering law if suspicions cannot be resolved.
Key dates
February 23, 2026
– SECO publishes Annex 8 amendments on its website
February 24, 2026, 11:00 PM UTC Deadline
– Changes take effect; financial intermediaries must immediately implement all prohibitions
H2 2026
– New organizational obligations under revised Money Laundering Act (GwG) requiring sanctions violation prevention measures take effect
Suggested considerations
*Implement all prohibitions specified in updated Annex 8 across all business lines and customer relationships
*Freeze assets of all newly designated natural persons and entities; block transactions with designated entities
*Report to SECO all affected business relationships within required timeframes, documenting:
Customer identification and beneficial ownership
Transaction history with designated parties
What changed
The February 2026 update to Annex 8 of the Ukraine Sanctions Ordinance introduces modifications to Switzerland's designated persons and entities list related to Russia sanctions.
22 natural persons and 42 companies/organizations subject to asset freezes and supply prohibitions
116 vessels (primarily tankers in Russia's shadow fleet circumventing oil price caps) subject to purchase, sale, and service prohibitions
45 companies in third countries subject to stricter export controls targeting critical goods for Russia's military-industrial complex
5 Russian banks and 4 foreign branches subject to transaction prohibitions due to use of Russian payment systems
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has appointed Alain Girard as the new Head of its Banks division. The current Head of the Recovery and Resolution division will take up his new role on 1 April 2026. He succeeds Thomas Hirschi, who left FINMA at the end of August 2025…
Why this matters
This regulatory update announces the appointment of a new head of FINMA's Banks division, which is a significant leadership change at the Swiss financial regulator.
More attractive working conditions and lower operating costs per workstation: FINMA will relocate its Zurich office from the city centre to Zurich-Oerlikon in autumn 2026.
Why this matters
This regulatory update from FINMA, the Swiss financial regulator, announces the relocation of its Zurich office to a new location in Oerlikon. The move is driven by the expiration of the current rental agreement and aims to reduce operating costs while providing more attractive working conditions.
In new guidance, the Swiss Financial Market Supervisory Authority FINMA explains how it assesses the risks associated with the custody of cryptobased assets. The guidance sets out the rules that institutions must abide by in order to keep cryptobased assets safe.
Der Bundesrat hat am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens über das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung über Massnahmen gegenüber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR…
AI Analysis
Switzerland has completely revised its Iran sanctions regulations effective December 12, 2025, restoring sanctions to pre-2015 levels following the automatic reinstatement of UN Security Council resolutions on September 28, 2025. This comprehensive overhaul requires Swiss financial institutions and businesses to immediately implement expanded asset freezes, trade restrictions, and sectoral prohibitions affecting Iran-related transactions and designated persons.
Key dates
September 28, 2025
- UN Security Council resolutions automatically reinstated (snapback mechanism triggered)
September 29, 2025
- EU reactivated suspended sanctions on Iran's proliferation activities
October 20, 2025
- Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings
October 21, 2025
- Updated sanctions list effective (23:00 UTC)
December 12, 2025
- Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)
Suggested considerations
*Immediate (Completed by December 12, 2025):
related transactions and accounts for compliance with expanded prohibitions
*Short-term (By January 1, 2026):
September 30, 2025 contracts under legacy exemption provisions
related transactions
What changed
The total revision introduces several critical regulatory shifts:
Scope Expansion: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803,...
In its new 2025 Risk Monitor, FINMA reveals where it sees the greatest risks for the Swiss financial centre. It warns of an increase in geopolitical and technological risks and calls for more robust controls over the outsourcing of critical functions. The climate risk report is also part of the Risk Monitor for the…
Why this matters
This regulatory update from FINMA highlights key risks for the Swiss financial sector, including geopolitical, cyber, and real estate risks. It also emphasizes the importance of robust controls over critical outsourcing functions.
Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europäischen Union (EU) gegenüber Russland sowie den zusätzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenüber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Güter-, Finanz und…
AI Analysis
On October 29, 2025, the Swiss Federal Council (Bundesrat) adopted comprehensive sanctions measures aligned with the EU's 18th sanctions package against Russia and additional measures against Belarus, effective October 30, 2025. This enforcement action significantly expands financial transaction prohibitions, export restrictions, and asset freezes, requiring Swiss financial intermediaries to immediately implement new compliance obligations across banking, goods trade, and energy sectors.
Key dates
October 29, 2025
- Federal Council decision adopted
October 30, 2025
- Measures effective date
Ongoing Deadline
- Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs)
Suggested considerations
*Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
*Freeze assets of all sanctioned persons and entities immediately upon notice
*Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
*Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
*Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy
What changed
Financial Sector Restrictions
The Bundesrat expanded transaction prohibitions on Russian banks substantially:
Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
Introduced new transaction prohibitions for 22 additional Russian banks
Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previously limited to RDIF-financed projects
Export...
The Swiss Financial Market Supervisory Authority FINMA today published guidance on the extension of the transitional period for exchange of collateral in certain OTC derivatives transactions. The current transitional period runs until 1 January 2026 and will be extended by a further three years.
AI Analysis
FINMA extended the transitional period for collateral exchange requirements in non-centrally cleared OTC derivatives from January 1, 2026 to January 1, 2029, providing Swiss market participants with three additional years of relief from mandatory collateral posting obligations on certain equity derivatives. This extension aligns Swiss regulation with the EU's indefinite exemption introduced in December 2024, preventing competitive disadvantages for Swiss derivatives traders while a permanent regulatory framework is developed.
Key dates
October 9, 2025
- FINMA Guidance 04/2025 published and takes effect immediately
January 1, 2029
- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted
Suggested considerations
*Acknowledge the extended timeline: Update internal compliance calendars and risk management frameworks to reflect the January 1, 2029 deadline rather than January 1, 2026.
*Monitor FinMIA revision: Track ongoing legislative developments regarding the permanent regulatory framework for OTC derivatives to prepare for post-2029 compliance requirements.
*Assess competitive positioning: Evaluate whether the extended transitional period affects trading strategies, counterparty relationships, or market competitiveness relative to EU and UK peers.
What changed
The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
Previous deadline: January 1, 2026
New deadline: January 1, 2029
Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or...
Regulatory basis: FINMA Guidance 04/2025, issued October 9, 2025, under authority granted by Article 131 paragraph 6 FinMIO
The extension does not eliminate the collateral exchange obligation;...
The Swiss Financial Market Supervisory Authority FINMA has identified further progress in UBS’s resolvability and continues to view a resolution as feasible. However, there is a need for greater optionality, which will also require legislative changes. UBS’s emergency plan largely fulfils the current statutory…
Why this matters
The regulatory update discusses progress in UBS's resolvability and the need for greater optionality, which will require legislative changes. This is relevant for banking and wealth management firms from a prudential and operational resilience perspective.
The Swiss Financial Market Supervisory Authority FINMA is transferring the FINMA Banking Insolvency Ordinance, FINMA Insurance Bankruptcy Ordinance and FINMA Collective Investment Schemes Bankruptcy Ordinance to a new consolidated FINMA Insolvency Ordinance. The existing regulations have been revised and adapted where…
Why this matters
This regulatory update from FINMA consolidates insolvency proceedings for financial institutions, including banks, asset managers, and wealth managers. It revises existing regulations based on practical experience, which impacts prudential requirements, operational resilience, and authorization/licensing for these...
The Swiss Financial Market Supervisory Authority FINMA has completed its annual assessment of the emergency and recovery plans for the domestic systemically important banks. The emergency plans for Zürcher Kantonalbank and Raiffeisen fulfil the regulatory requirements. The emergency plan for PostFinance is still not…
Why this matters
This regulatory update from FINMA assesses the emergency and recovery plans for three domestic systemically important banks in Switzerland - PostFinance, Raiffeisen, and Zürcher Kantonalbank. This is relevant for the banking and payments sectors, as it relates to prudential requirements and operational resilience.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 11. November 2015 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.
AI Analysis
On August 18, 2025, the Swiss State Secretariat for Economic Affairs (WBF) published an updated sanctions notification regarding Iran, specifically modifying Annex 7 of the Ordinance on Measures against the Islamic Republic of Iran (SR 946.231.143.6). This update is critical for Swiss financial institutions and businesses because it reflects the evolving sanctions landscape following the automatic reinstatement of UN Security Council resolutions on Iran's nuclear program in September 2025.
Key dates
August 18, 2025
- WBF published updated sanctions notification for Iran (Annex 7 modifications)
August 28, 2025
- Germany, France, and UK triggered UN snapback mechanism
September 15, 2025
- Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)
September 27, 2025
- UN nuclear-related sanctions against Iran automatically reinstated
September 28, 2025
- EU reactivated suspended sanctions related to Iran's proliferation activities
Suggested considerations
*Immediate compliance obligations:
*Sanctions List Screening: Update all sanctions screening systems and databases to reflect the August 2025 Annex 7 modifications and subsequent December 2025 total revision
*Transaction Review: Conduct comprehensive review of existing Iranian counterparties, customers, and beneficiaries against updated FINMA-published lists
*Account Monitoring: Identify and freeze accounts or assets belonging to designated persons and entities; report frozen assets to authorities
*Reporting: File mandatory notifications with FINMA and relevant authorities regarding any identified matches or transactions with sanctioned parties
What changed
The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG).
The broader context shows that Switzerland was preparing for significant sanctions escalation: on December 12, 2025, the Swiss Federal Council conducted a total...
Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.
AI Analysis
The Swiss State Secretariat for Economic Affairs (SECO) published an updated sanctions notification on August 13, 2025, reflecting modifications to the UN sanctions list targeting Iraq under the Ordinance of August 7, 1990 (SR 946.206). This update is automatically applicable in Switzerland and requires immediate compliance by all financial institutions and regulated entities, as Switzerland implements UN Security Council sanctions lists without delay through its automatic application framework.
Key dates
August 5, 2025
- UN Sanctions Committee decision modifying the Iraq sanctions list
August 13, 2025
- SECO published the updated sanctions notification and SESAM database modifications
Immediate
- Effective date in Switzerland (automatic application upon UN modification)
Suggested considerations
*Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
*Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
*Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
*Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
*Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements
What changed
The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Council sanctions lists enter into force in Switzerland without delay.