Trustee due diligence questionnaire: the questions to send and the answers to expect

A trustee due diligence questionnaire is a written list of questions that you send to every candidate trustee before you appoint one, or before you decide whether to keep the one you have. The value lies less in any single question than in asking the same ones of everybody and reading the replies against an answer you decided in advance.

This page gives you that list for a trustee based in Switzerland, grouped by theme, with the reply to look for next to each question. It is general information. How much weight each question deserves depends on your residence, the country of your beneficiaries, the kind of assets and the canton, and an individual analysis should confirm it.

How to use the questionnaire

Send the questions in writing and ask for written replies. A conversation is useful, but a reply on paper can be compared, filed and shown to an adviser later. Keep a copy with your trust papers.

Three habits make the exercise worthwhile:

• Decide the acceptable answer first. Write down what you would be happy to read before the replies arrive. Otherwise the most fluent candidate tends to win, not the most suitable one.
• Ask for evidence, not assurances. A statement such as "we are fully compliant" is only a claim. A named supervisory body, a described procedure or a document you can read is evidence.
• Note what is missing. A question left unanswered, or answered with a different question, is information too.

If you want the wider method before you send anything, read how to choose a trustee in Switzerland and the twelve steps to choose a trustee. This questionnaire is the written instrument that sits inside that process.

Question and acceptable answer at a glance

The diagram below condenses the core of the questionnaire. Each row is a question; the columns show what a sound reply looks like and what should make you pause.

The questions, theme by theme

1. Authorisation and supervision

A trustee operating in Switzerland as a professional is, under the financial institutions framework (FinIA, known in French as LEFin and in German as FINIG), expected to be authorised and supervised. The FINMA list of authorised asset managers and trustees records the supervisory organisation behind each firm. Organisations named on the list include OSFINcontrol AG, AOOS, SO-FIT and OSIF.

Ask:

• Under which authorisation do you act as a trustee, and with which supervisory organisation are you affiliated?
• Can you point me to your entry on the public FINMA list?
• Has your supervisory organisation or FINMA ever imposed a measure on your firm that you are able to disclose?

Acceptable answer: the firm names its organisation, points to the public list and answers the last question directly. For what approval does and does not tell you, see FINMA and SO-FIT: what trustee approval means for you.

2. Anti-money-laundering duties

Under the Anti-Money Laundering Act (AMLA, in French LBA, in German GwG), asset managers and trustees within the scope of FinIA count as financial intermediaries. Several duties follow for the firm, and you will feel them as requests for documents:

• Identifying the contracting party on the basis of a supporting document when the relationship begins.
• Identifying the beneficial owner with the required diligence and checking the identity, with a written declaration when the contracting party is not the beneficial owner or when there is doubt.
• Drawing up and keeping records, and having organisational measures in place.

Ask:

• How do you identify and verify the settlor, the beneficiaries and the beneficial owner?
• What documents will you require from us, and why?
• Where are the records kept, and who can access them?

Acceptable answer: a candidate who asks for documents and explains the reason is applying the rules. One who waves them away is a worse sign than one who asks for a lot. Treat a trustee who never asks about the source of the assets with caution.

3. People and continuity

Ask:

• Who will be my day-to-day contact, and who is the deputy?
• What happens if that person leaves the firm, falls ill or dies?
• For an individual trustee: what is the succession arrangement for the role?

Acceptable answer: named people, a deputy, and a stated continuity arrangement. The point is developed in continuity planning when the trustee is not there, and the term is explained under successor trustee.

4. Decisions, records and reporting

Ask:

• How are distribution and investment decisions taken and recorded?
• Will I receive accounts, and how often?
• What information can beneficiaries ask for, and how do you handle those requests?

Acceptable answer: a written process, minutes that state reasons, and a fixed reporting rhythm. What you can expect to receive is covered in the information your trustee must give you.

5. Conflicts and independence

Ask:

• Do you or an affiliated company receive any payment from the trust's service providers, banks or advisers?
• How do you deal with a conflict between a settlor's wishes and a beneficiary's interests?
• Do you act for other members of the same family?

Acceptable answer: open disclosure and a written policy. A trustee that says conflicts never arise has not looked for them.

6. Remuneration

Honest candidates explain how they charge before you sign. Ask which basis applies to your structure, what is included, and what is billed separately. The amounts depend on the structure and are given after a confidential assessment, so do not expect a number in a first reply; expect a method. The main models are compared in trustee fee models side by side.

Acceptable answer: a written basis that you can read, with the extras identified.

7. Exit

Ask:

• What is your procedure if I want to change trustee?
• What do you hand over, and in what form?
• Do you hold anything back pending a dispute?

Acceptable answer: a described handover and cooperation in the deed of retirement and appointment. A candidate who is vague about leaving is signalling how leaving would feel.

A note on the transparency register

A federal register of beneficial owners, run by the Federal Office of Justice, started on 1 October 2026. The official announcement speaks of legal entities and does not mention trusts, so do not assume it replaces what a trustee collects. Ask the candidate how, in practice, the register affects any company held in your structure.

One filled-in line

The line below shows how a completed row can look. The example is fictional: a family established in Lausanne is choosing between two candidates.

The family asks B again, in writing. If the second reply still names nothing, the question has done its job.

Printable version

Print this page and tick the lines as the replies arrive. The checklist keeps one question per line, in the order of the themes above.

• The candidate names its FINMA authorisation and supervisory organisation
• The entry can be found on the public FINMA list
• The candidate explains how it identifies the settlor, the beneficiaries and the beneficial owner
• A written declaration is requested when the contracting party is not the beneficial owner
• Record-keeping and access are described
• A named day-to-day contact and a named deputy are given
• A continuity arrangement exists for absence, illness or death
• Decisions are recorded in writing with reasons
• A reporting rhythm is stated and put in writing
• A conflicts policy is shared and disclosures are described
• The remuneration basis is written and the extras are identified
• A handover procedure and a deed of retirement and appointment are described
• Every question was answered, none sidestepped

Once the replies are in, a second pair of eyes helps. An independent review of an existing trust and its trustee reads the deed, the records and the tax position together, and the longer discussion in due diligence on your trustee explains what to do with a weak reply.