FINMA Flags Product Risks In Portfolio Management

On 3 June 2026, FINMA published Guidance 03/2026 on the risks associated with the use of products in individual portfolio management. The Guidance responds to a rise in cases escalated to FINMA due to deficiencies (escalation cases) concerning portfolio managers licensed under Article 17 FinIA. Although primarily addressed to such portfolio managers, FINMA stresses that its findings are also relevant to other institutions providing individual portfolio management, including without limitation managers of collective assets, securities firms, and banks.

Findings from the escalation cases

FINMA’s analysis revealed recurring risk patterns, particularly in connection with in-house products, products lacking equivalent supervision and unsupervised structures. The instruments most frequently involved were foreign funds without equivalent supervision, structured products (in particular actively managed certificates, AMCs) and securities of foreign, unregulated issuing or structuring