On 1 November 2016, FINMA published the revised circulars 2008/21 on “Operational risks – banks” and 2010/1 on “Remuneration schemes” which both have been revised in the context of the new FINMA circular 2017/1 “Corporate governance – banks”. The most significant changes pertain to i) the adoption of minimum requirements for the regulation of IT and cyber risks in the revised circular 2008/21 as well as ii) a narrowed scope of application and the prohibition of hedge transactions in the revised circular 2010/1. Both revised circulars will enter into force on 1 July 2017.

By Peter Ch. Hsu / Sandro Fehlmann (Reference: CapLaw-2017-26)