Reminder: Be prepared for your next regulatory audit

Delegation of regulatory material tasks (art. 66 CISO-FINMA) must be reflected in your organizational documents

Rules in relation to any kind of delegation had been introduced by Art. 66 CISO-FINMA in 2015 to provide a similar requirement for CISA licensees as set out for banks in the FINMA Circular 2008/7 «Outsourcing – Banks» (which is currently under revision). The licensees covered by Art. 66 CISO-FINMA are fund management companies, investment Companies with variable capital (SICAVs), asset managers of collective investment schemes and representatives of foreign collective investment schemes (hereinafter «the licensee(s)»).

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For more information please contact us:

Günther Dobrauz
Partner, Leader Legal FS Regulatory &
Compliance Services
+41 58 792 14 97

Sabine Bartenschlager-Igel
Senior Manager, Legal FS Regulatory &
Compliance Services, Head Asset Management
+41 58 792 28 73

Anne Batliner
Manager, Legal FS Regulatory &
Compliance Service
+41 58 792 29 55

Published by

Guenther Dobrauz

Guenther Dobrauz

Guenther Dobrauz
Birchstrasse 160
Postfach, 8050 Zurich
+41 58 792 14 97

Guenther leads the PwC Legal Services Practice in Switzerland and the Legal FS Regulatory & Compliance Services department. He is a PwC Partner since 2015 and a global expert on legal advisory, specializing in supporting the structuring, authorization and ongoing lifecycle management of financial intermediaries and their products. He in particular also focuses on leading large scale regulatory change and compliance alignment projects.

Guenther is the author of books on investment selection, FinTech Regulation and European, Swiss and Liechtenstein investment law. He also wrote 80+ publications in international expert magazines and has to date been speaking at more than 60 conferences worldwide.

Guenther Dobrauz received his Masters and PhD degrees in law from Johannes Kepler University (Linz, Austria). He holds an MBA from the University of Strathclyde Graduate School of Business (Glasgow, UK) and has participated in Harvard Business School’s Executive Education Program.

Guenther Dobrauz was Legal Counsel of an international hedge fund group and served as Managing Partner and Legal Counsel of a Swiss Venture Capital firm. He has practiced in court and with a leading business law firm.