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Swiss financial institutions, already licensed by FINMA prior to 1st January 2020 must take the following actions under the newly enacted Federal Act on Financial Services (“FINSA”) and Federal Act on Financial Institution (“FINIA”) and their respective ordinances are the following:

  1. Registration with a Mediation Body, last deadline: 30 June 2020 (or any extended deadline) (Sections 77and 95 para. 3 FINSA and 108 FINSO)

  2. Comply with all rules of conduct according to the law, last deadline: 31 December 2021 (Section 105 para. 1 FINSO)

  3. Comply with the organisational requirements according to the law, last deadline: 31 December 2021(Section 106 para. 1 FINSO)

  4. Keep your regulatory auditors informed as to the progress of actions 1 to 3.

DO YOU NEED HELP? lecocqassociate is available to assist you in the entire process. Feel free to contact Lucile Cesareo-Hostettler or Dominique Lecocq ( for any questions.

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