Trustee compliance and reporting duties: what your trustee must do

If your trust sits with a trustee in Switzerland, you will be asked for documents, sometimes more than you expected. The requests are not a courtesy check. They come from the trustee's compliance and reporting duties, which are set by law and supervised. Understanding them makes the process faster and shows you what a careful trustee looks like.

This page explains what the trustee must do, what it will ask you for, and why. It describes the work of the trustee only; your own tax position depends on where you and your beneficiaries live and needs individual analysis.

Why a Swiss trustee has these duties

A professional trustee in Switzerland is a regulated financial institution. Under the financial institutions law (FinIA, LEFin, FINIG), trustees are listed alongside asset managers, and they are subject to FINMA supervision, with day-to-day oversight carried out by a supervisory organisation authorised by FINMA. An annual audit by an audit firm completes the picture.

The anti-money-laundering law (AMLA, LBA, GwG) goes further: trustees and asset managers referred to in the financial institutions law are financial intermediaries. That status brings the duties described below, and it applies to the relationship with you from the very first contact.

A self-regulatory body such as SO-FIT, authorised by FINMA, acts both as an anti-money-laundering body and as a prudential supervisory organisation for trustees and asset managers. In practice, your trustee answers to a framework, not to its own preferences.

What the trustee has to do

Five tasks sit at the centre of the service.

1. Identify the settlor, the beneficiaries and the controlling persons

The AMLA requires the trustee to verify the identity of its contracting party when a business relationship is established, on the basis of supporting documents. It must also identify the beneficial owner with the diligence the circumstances require, and verify that person's identity. Where the contracting party is not the beneficial owner, or where there is doubt, a written declaration is required.

For a trust, this usually means the settlor, the beneficiaries or the class of beneficiaries, a protector if there is one, and anyone else who can steer the assets or the trustee.

2. Assess the risk of the relationship

Not every trust carries the same risk. The trustee looks at who the parties are, where they live, what the assets are and where they come from, and what the structure is for. A simple family arrangement and a layered structure with several companies do not call for the same depth of review.

3. Screen the parties and the origin of assets

Names are screened and the source of the assets is documented. Expect questions about how the wealth was built, not only where it is held today.

4. Classify the structure for information exchange and file

The trustee determines how the trust is treated for automatic exchange of information (AEOI, EAR, CRS) and for related regimes, and then files the reports that follow from that classification. The classification depends on the facts of the trust and of the people involved.

5. Monitor unusual activity

A relationship is not checked once and forgotten. The trustee watches for unusual movements or changes and keeps the file current. The law also obliges the trustee to establish and keep records, and to maintain organisational measures to apply the rules.

What the trustee asks you for, and when

The first request comes at onboarding: identity documents, a description of the structure, the trust deed and a short account of where the assets come from. Later requests come when something changes: a new beneficiary, a change of residence, a new protector, a large distribution or a new bank account.

Trustees also refresh files on a regular cycle, as part of the yearly compliance review. A request to update documents does not mean something is wrong; it means the file must reflect today's facts.

Example: a family established in Lausanne has had a trust for many years. One of the adult children moves abroad and the settlor appoints a new protector. The trustee asks for new identification papers, a fresh declaration about who benefits, and updated tax residence details, then records the new classification. Nothing is wrong with the trust; the file is simply refreshed.

If the settlor relocates, the trustee's role when the settlor moves country is worth reading, as is the page on questions for a US person if any party has US ties.

A note on the new transparency register

Switzerland's law on the transparency of legal entities and the identification of beneficial owners came into force, and the register kept by the Federal Office of Justice started on 1 October 2026. The official announcement speaks of legal entities and does not mention trusts. Whether and how your structure is affected depends on its components, for instance a company held by the trust, which is a matter for individual analysis.

What this service does not cover

The service covers the trustee's own compliance work. It does not provide tax advice for your country of residence, and it does not file your personal tax return. Bank-side requirements are a separate relationship, although the trustee often coordinates them; see your trustee and the trust bank accounts.

What a confidential assessment can establish

A confidential assessment can show which of your current documents meet the trustee's standards, what is missing, who counts as a controlling person in your structure, and how the relationship would be classified for exchange of information. It can also help you compare what your present trustee asks for with the due diligence questions you should expect. Fees depend on the structure and are indicated after the assessment.