AWS is pleased to announce the publication of the AWS User Guide to Financial Services Regulations and Guidelines in Switzerland whitepaper and workbooks.

This guide refers to certain rules applicable to financial institutions in Switzerland, including banks, insurance companies, stock exchanges, securities dealers, portfolio managers, trustees and other financial entities which are overseen (directly or indirectly) by the Swiss Financial Market Supervisory Authority (FINMA).

Amongst other topics, this guide covers requirements created by the following regulations and publications of interest to Swiss financial institutions:

  • Federal Laws – including Article 47 of the Swiss Banking Act (BA). Banks and Savings Banks are overseen by FINMA and governed by the BA (Bundesgesetz über die Banken und Sparkassen, Bankengesetz, BankG). Article 47 BA holds relevance in the context of outsourcing.
  • Response on Cloud Guidelines for Swiss Financial institutions produced by the Swiss Banking Union, Schweizerische Bankiervereinigung SBVg.
  • Controls outlined by FINMA, Switzerland’s independent regulator of financial markets, that may be applicable to Swiss banks and insurers in the context of outsourcing arrangements to the cloud.

In combination with the AWS User Guide to Financial Services Regulations and Guidelines in Switzerland whitepaper, customers can use the detailed AWS FINMA workbooks and ISAE 3000 report available from AWS Artifact.

The five core FINMA circulars are intended to assist Swiss-regulated financial institutions in understanding approaches to due diligence, third-party management, and key technical and organizational controls that should be implemented in cloud outsourcing arrangements, particularly for material workloads. The AWS FINMA workbooks and ISAE 3000 report scope covers, in detail, requirements of the following FINMA circulars:

  • 2018/03 Outsourcing – banks and insurers (04.11.2020)
  • 2008/21 Operational Risks – Banks – Principle 4 Technology Infrastructure (31.10.2019)
  • 2008/21 Operational Risks – Banks – Appendix 3 Handling of electronic Client Identifying Data (31.10.2019)
  • 2013/03 Auditing – Information Technology (04.11.2020)
  • 2008/10 Self-regulation as a minimum standard – Minimum Business Continuity Management (BCM) minimum standards proposed by the Swiss Insurance Association (01.06.2015) and Swiss Bankers Association (29.08.2013)

Customers can use the detailed FINMA workbooks, which include detailed control mappings for each FINMA control, covering both the AWS control activities and the Customer User Entity Controls. Where applicable, under the AWS Shared Responsibility Model, these workbooks provide industry standard practices, incorporating AWS Well-Architected, to assist Swiss customers in their own preparation for FINMA circular alignment.

This whitepaper follows the issuance of the second Swiss Financial Market Supervisory Authority (FINMA) ISAE 3000 Type 2 attestation report. The latest report covers the period from October 1, 2020 to September 30, 2021, with a total of 141 AWS services and 23 global AWS Regions included in the scope. Customers can download the report from AWS Artifact. A full list of certified services and Regions is presented within the published FINMA report.

As always, AWS is committed to bringing new services into the scope of our FINMA program in the future based on customers’ architectural and regulatory needs. Please reach out to your AWS account team if you have any questions or feedback. If you have questions about this post, contact AWS Support.

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Author

Margo Cronin

Margo is a Principal Security Specialist at Amazon Web Services based in Zurich, Switzerland. She spends her days working with customers, from startups to the largest of enterprises, helping them build new capabilities and accelerating their cloud journey. She has a strong focus on security, helping customers improve their security, risk, and compliance in the cloud.