Marketing a Private Fund in Switzerland: Compliance with CISA Required from 1 March 2015
The revised Swiss Collective Investment Schemes Act (“CISA”) entered into force on 1 March 2013. Switzerland has not joined the European Economic Area and is therefore not required to implement the Alternative Investment Fund Managers Directive (“AIFMD”). Fund managers marketing private funds to investors in Switzerland are subject to compliance with CISA, not AIFMD, in respect of such activities.
Until now, fund managers marketing fund interests into Switzerland have generally benefited from a transitional period during which compliance with certain provisions of CISA was not required.
This transitional period ends this week. Fund managers marketing to investors in Switzerland on or after 1 March 2015 will now need to consider whether they are subject to CISA and, if so, take appropriate steps to ensure compliance.