The SEC Reopens Registration Pathway for Swiss Investment Advisers

New opportunities are available for Swiss-based firms seeking access to U.S. markets.

Since the introduction of GDPR by the European Union (EU) in May 2018, EU-based investment advisers, including those in Switzerland, have faced a major hurdle accessing the U.S. The SEC placed a moratorium on approving their registration filings due to GDPR’s strict data privacy rules, which prevented advisers from sharing personal data and other records directly with SEC staff. In some cases, GDPR also restricted the SEC’s ability to conduct on-site examinations, creating a compliance impasse between U.S. securities laws and European privacy regulations.

SEC Resumes Swiss Registrations

On June 10, 2025, the SEC announced that it will resume processing new and pending registration applications from investment advisers whose principal office and place of business is in Switzerland.

This decision follows successful negotiations between the SEC and the Swiss Financial Market Supervisory Authority (FINMA), which have resolved the regulatory barriers that previously prevented Swiss advisers from registering under the Investment Advisers Act of 1940.

Why Registration With the SEC Matters

Becoming a registered investment adviser (RIA) with the SEC offers several strategic advantages:

  • Access to U.S. Clients: RIAs can provide investment advice to U.S. persons, including institutional investors and separately managed accounts.
  • Eligibility for U.S. Funds: RIAs may advise collective investment vehicles registered in the U.S., such as mutual funds and business development companies.
  • Enhanced Credibility: SEC registration signals a commitment to regulatory compliance and can enhance an adviser’s reputation in global markets.
  • Defined Compliance Framework: Operating under the SEC’s regulatory structure provides clarity and consistency in compliance expectations.

Next Steps

Swiss advisers interested in SEC registration should begin preparing their Form ADV filings. With the moratorium lifted, this is a timely opportunity to re-engage with the U.S. market. Engaging experienced compliance professionals can help ensure a smooth and efficient registration process.

How We Help

SEC registration and ongoing compliance can be complex and time-consuming, especially for firms operating across jurisdictions. Reach out to our London-based SEC compliance specialists, who are uniquely positioned to support Swiss investment advisers locally as they pursue registration and build their U.S. compliance programs.

We have helped hundreds of non-U.S. firms register with the SEC, and our team regularly works with clients to incorporate an SEC compliance program into their existing compliance framework. Our services include:

  • Initial SEC Registration Support: We guide firms through the full registration process, including the preparation and filing of Form ADV and the development of SEC compliance policies and procedures that are tailored to each firm’s specific business model.
  • Ongoing Compliance Support: Post-registration, we provide a full suite of services including ongoing consulting and regulatory updates, annual compliance reviews, mock SEC examinations, training, marketing review, SEC filing support, SEC examination support, and Chief Compliance Officer outsourcing.
  • Compliance Technology and Managed Services: We streamline compliance tasks and enhance oversight through ComplianceAlpha®, our award-winning RegTech platform. Additionally, our Managed Services provide flexible, outsourced compliance support, ideal for firms focused on launching and scaling in the U.S. market.

Connect with us today to book a meeting with a UK-based SEC specialist.

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