On 19 March 2025, FINMA published Circular 2025/4 on the consolidated supervision of financial groups. This circular is based in particular on Articles 3g of the BA and 24 of the BO, as well as Article 49(3) of the FinIA (which provides for the analogous application of the BA's provisions on financial groups and conglomerates to securities firms). These provisions authorise FINMA to issue regulations in this area and to monitor compliance, while granting the supervisory authority broad discretion in their practical application. Circular 2025/4 will enter into force on 1 July 2025.
Vaïk Müller, Partner and Head of the Banking & Finance department at CMS Geneva, analyses the implications in an article published in Point de Mire magazine on 25 June 2025.
Read Vaïk Müller's article on the Point de Mire website (only available in French):
