FINMA

Swiss Financial Market Supervisory Authority

High Impact

FINMA enforcement action underscores FinSA conduct, conflict and suitability controls for Swiss asset management

Published

Jun 29, 2026

Topics

FinSA conduct rules, Conflicts of interest, Appropriateness and suitability, Asset management, Collective asset management, Portfolio manager authorisation, Enforcement, Investor protection

Executive Summary

FINMA has concluded enforcement proceedings against Swiss Fund Management AG in liquidation, BZ Berater Zentrum AG and one responsible individual after finding serious breaches of FinSA conduct obligations. The case centred on substantial client and fund exposure to illiquid bonds issued by affiliated, non-operational entities and used largely to finance overseas real estate development projects. FINMA found that investors were not adequately informed about inherent conflicts of interest and that investments were concentrated in unsuitable own or affiliated products inconsistent with client risk profiles and pension-provision objectives. FINMA revoked SFM’s licence as a manager of collective assets, appointed Grant Thornton AG as liquidator, rejected BZ’s application for authorisation as an independent portfolio manager and required BZ to cease asset management activity within 30 days of notification. FINMA also ordered confiscation of over CHF 3 million in illegally generated commission and imposed a multi-year industry ban on one individual. The ruling was not appealed within the appeal period and has entered legal effect.

What Changed

modifiedSwiss Fund Management AG licence status

SFM held a FINMA licence to manage collective assets, although it was already in liquidation.

New

The licence has been withdrawn and the investigating agent Grant Thornton AG has been appointed as liquidator.

modifiedBZ Berater Zentrum AG authorisation and activity status

BZ had applied for authorisation as an independent portfolio manager while FINMA supported and monitored its business activities through precautionary measures during the investigation.

New

The authorisation application was rejected and BZ had to cease asset management activities within 30 days of notification of the ruling.

newConfiscation and individual industry ban

No concluded FINMA confiscation or industry-ban measure had been announced in this matter.

New

FINMA is confiscating over CHF 3 million in illegally generated commission from BZ and an involved individual and imposed a multi-year industry ban on one responsible individual.

modifiedFINMA application of FinSA conduct expectations

FinSA conduct rules already required financial service providers to comply with duties including suitability, appropriateness and conflict management.

New

FINMA found serious breaches where client money was invested in concentrated, illiquid affiliated bonds without adequate conflict disclosure and contrary to investor risk profiles and pension objectives.

newOmbudsman mediation pathway for affected BZ clients

Around 150 people had initiated mediation proceedings against BZ while FINMA’s enforcement proceedings were ongoing.

New

OFS Ombud Finance Switzerland has decided to commence mediation with those individuals following conclusion of FINMA’s proceedings.

Business Impact

Who is affected

Directly affected

Swiss Fund Management AG in liquidation, BZ Berater Zentrum AG, the responsible individual subject to an industry ban, and SFM/BZ clients and investors exposed to the relevant illiquid bonds.

Indirectly affected

Swiss financial service providers, managers of collective assets, portfolio managers, investment advisers, distributors, compliance teams, internal audit teams, custodians and platforms with exposure to private debt, affiliated products or Swiss asset-management counterparties.

Jurisdictions

Switzerland

Business processes

Client suitability and appropriateness assessment, Conflict-of-interest identification, mitigation and disclosure, Related-party issuer and own-product governance, Illiquid bond and private-debt product due diligence, Portfolio concentration and diversification monitoring, Licence and authorisation status monitoring, Fee, commission and inducement controls, Client complaints and ombudsman coordination

Estimated effort

Medium

Compliance risk

High

Affected Reports

Suitability and appropriateness assessment file for advised or managed portfoliosConflict-of-interest register and client disclosure evidenceIlliquid/private bond product due diligence and valuation review fileRelated-party exposure and portfolio concentration monitoring controlCounterparty licence and authorisation status monitoring control

Field	Validation rule
Client risk profile and pension-provision objective	Controls should evidence that recommended or managed investments are consistent with the client’s risk profile and stated investment objective; FINMA found the relevant illiquid bonds unsuitable for investors in this case.
Issuer affiliation and related-party links	Controls should identify and escalate affiliations between issuers, asset managers, advisers and beneficiaries because FINMA found undisclosed interdependencies and inherent conflicts of interest.
Product liquidity and valuation uncertainty	Due diligence should flag illiquid bonds of uncertain value, particularly where repayment depends on real estate development projects.
Portfolio concentration in own or affiliated products	Monitoring should identify non-diversified exposure to own, affiliated or self-interested products inconsistent with client needs.
Commission or placement remuneration	Fee controls should identify commission from conflicted product placement; FINMA confiscated over CHF 3 million in illegally generated commission in this matter.

Recommended Actions

7 suggested next steps· derived from source analysis

1
AI generatedStep 1 of 7
Identify any client, fund, custody or platform exposure to SFM, BZ, the relevant illiquid bonds or affiliated issuers, and preserve suitability, disclosure and transaction records.
2
AI generatedStep 2 of 7
Re-test conflict-of-interest controls for own products, affiliated issuers, related-party financing chains and compensation arrangements, including whether client disclosures are specific and evidenced.
3
AI generatedStep 3 of 7
Review suitability and appropriateness governance for illiquid, concentrated or private-debt investments, especially where products are used for pension-oriented clients or lower-risk mandates.
4
AI generatedStep 4 of 7
Update product due diligence standards to require evidence on issuer operations, use of proceeds, security package, valuation basis, liquidity and dependencies on real estate development outcomes.
5
AI generatedStep 5 of 7
Strengthen management information on portfolio concentration in affiliated products and require escalation where financial self-interest may conflict with client outcomes.
6
AI generatedStep 6 of 7
Add FINMA authorisation, enforcement and liquidation status checks to onboarding and periodic review of Swiss asset managers, portfolio managers and product counterparties.
7
AI generatedStep 7 of 7
For affected or potentially affected clients, coordinate complaint handling, legal hold and ombudsman response workflows with OFS Ombud Finance Switzerland processes where applicable.

Timeline

other

2024

FINMA initiated enforcement proceedings against SFM and BZ after supervisory findings and an on-site inspection at SFM; FINMA appointed an investigating agent and imposed precautionary measures during the investigation.

implementation

May 1, 2026

FINMA concluded the enforcement proceedings and ordered measures, including licence withdrawal, authorisation rejection, liquidation appointment, confiscation and an industry ban.

implementation

Date not specified

BZ was required to cease asset management activities within 30 days of notification. FINMA did not disclose the notification date in the press release.

publication

Jun 29, 2026

FINMA published the press release announcing the concluded proceedings and stating that the ruling was not appealed within the appeal period and had entered legal effect.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Press releaseSwiss Financial Market Supervisory Authority FINMAJun 29, 2026
FINMA concludes proceedings against Swiss Fund Management AG in liquidation and BZ Berater Zentrum AG and enforces rules of conduct in the financial services sector ↗
https://www.finma.ch/en/news/2026/06/20260629-mm-durchsetzung-verhaltensregeln
Primary legislationThe Federal Council / FedlexJun 15, 2018
Financial Services Act (FinSA), SR 950.1 ↗
https://www.fedlex.admin.ch/eli/cc/2019/758/en

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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