Insights
Notes on fit-and-proper obligations, the nFADP and what a defensible verification programme actually contains.
FINMASA Art. 3 and FINMA Circular 2017/1 impose an ongoing fit-and-proper obligation. A one-off hiring check does not discharge it. Here is what the obligation actually requires.
Read moreVerifying existing staff periodically rests on a different legal footing than an onboarding check. Here is how nFADP Art. 31 (overriding interest) applies — and what the notice-and-consent requirement means in practice.
Read moreLimiting periodic verification to publicly available sources is not just an ethical choice — it is the legally correct methodology under nFADP Art. 6 and the foundation of an auditable programme.
Read moreRunning the same covered population every cycle and delivering the same findings is noise, not intelligence. Delta analysis focuses the Compliance Officer's attention on what is genuinely new.
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