In March 2018 the U.S. Congress enacted the U.S. Cloud Act. From an EU-perspective there is significant concern that U.S. authorities might undermine the EU GDPR requirements by compelling U.S. providers to allow access to certain types of data stored outside the U.S.
Use of trusts is widespread in English-speaking countries. Foreign trusts are both in demand and in use in Switzerland as well. Today, the National Council debated whether trusts should be included in the Swiss legal framework.
The revised FINMA circular 2018/3 “Outsourcing - Banks” has now been in effect for nearly a year. Experience has shown that institutions are having a hard time particularly with the risk-oriented monitoring of their outsourcing providers (including any sub-contractors these may have hired).