CapLaw-2026-56

FINMA has intensified its enforcement of the conduct obligations governing individual financial services under the Financial Services Act (FinSA). The publicly communicated conclusions of two recent enforcement proceedings are good examples of interventions by the regulator under the FinSA conduct regime. Accompanied by FINMA Guidance 03/2026, which highlights recurring risk patterns, these cases signal that the conduct obligations are now firmly on FINMA‘s enforcement radar.