On June 10, 2025, the US Securities and Exchange Commission (SEC) announced that it will immediately resume processing new and pending registration applications of investment advisers with their principal office and place of business in Switzerland.
This development is the result of discussions between staff from the SEC and the Swiss Financial Market Supervisory Authority (FINMA) regarding (1) the ability of FINMA-supervised, SEC-registered investment advisers located in Switzerland to provide their books and records—including personal data—directly to SEC staff, and (2) the SEC's ability to conduct on-site visits of these entities in Switzerland, consistent with US securities laws and Swiss law.
Registration applications for Swiss-based investment advisers have been held in abeyance for years, pending the resolution of these issues, which has been a point of significant frustration for global financial services firms and other industry participants. The SEC previously took a similar position with respect to UK-based investment advisers. However, beginning in September 2020, registration applications from these advisers began to move forward, as a result of developments between the SEC and the UK Information Commissioner's Office regarding the above two topics. New registrations of advisers located in other jurisdictions subject to broad privacy regimes, including the European Union's General Data Protection Regulation (GDPR) continue to remain on hold at this time.
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