FinSA&FinIA oblige FINMA to issue a number of implementing provisions regarding mainly technical issues. According to a FINMA press release dated 7 February 2020, existing FINMA ordinances and circulars are going to be amended and three circulars will be abolished. In addition, a new Financial Institutions Ordinance-FINMA will be created (FinIO-FINMA).

In particular, the FinIO-FINMA defines the requirements for professional indemnity insurance for asset managers, trustees and managers of collective assets, provides details of the calculation of the de minimis thresholds with regards to the authorization of asset managers and managers of collective assets and contains implementing provisions on risk management and internal control systems for managers of collective assets.

FINMA also recommends lowering the thresholds for client identification for exchange transactions in cryptocurrencies from CHF 5,000 to CHF 1,000. According to FINMA, this adjustment considers new international standards and increased money laundering risks in the cryptocurrencies space.

Currently, the FINMA does not intend to release an ordinance relating to the FinSA.

FINMA will conduct a public hearing on the proposals by April 9, 2020. The adjustments shall be adopted in the fourth quarter of this year.