The five frames at a glance
Five frames interlock. FinSA governs investor classification (retail / professional / institutional), disclosure and suitability — and thereby which opportunities may lawfully be offered to you. CISA defines the "qualified investor" for non-publicly distributed collective schemes. The GwG (AMLA) requires identification, determining the beneficial owner and establishing the source of funds. The DLT Act, via the ledger-based security (Registerwertrecht), is the legal basis for tokenised instruments. The FADP governs the processing of personal data.
FinSA — who may be offered what?
FinSA requires every provider to classify a client before serving them: retail, professional or institutional. For private markets this is decisive, because classification governs which — often non-public — opportunities may lawfully be offered. Individuals can opt out (Art. 5) into professional treatment. OwnMore addresses qualified and professional investors only (FinSA Art. 10 / Art. 3); Art. 4 retail distribution is not supported.
CISA — the "qualified investor"
The Collective Investment Schemes Act (CISA) defines the parallel concept of the qualified investor and restricts who may be offered non-publicly distributed collective schemes — deliberately aligned with the FinSA segments. "Professional/institutional" are FinSA terms; "qualified investor" is the CISA term.
AMLA / GwG — KYC as a structural gate
The Anti-Money-Laundering Act requires: identify the contracting party, determine the beneficial owner (for operating companies, typically whoever directly/indirectly holds over 25% or otherwise controls; for trusts/foundations, the controlling persons and beneficiaries), establish the source of funds, apply enhanced diligence to higher risk (PEPs, high-risk jurisdictions), keep records and monitor. The GwG revision (TJPG, adopted by Parliament on 26 September 2025) adds a non-public federal beneficial-ownership transparency register and extends due-diligence duties to certain higher-risk advisory and intermediary activities. At OwnMore this check is today manual and four-eyes; automated AML/PEP/sanctions screening is in preparation.
DLT Act — ledger-based securities & tokenised participation
The DLT Act introduced the ledger-based security into the Code of Obligations in 2021 — a ledger-native security held on, and transferred only through, a qualifying securities ledger. It is the Swiss legal basis for tokenised/digitally settled instruments. Importantly, tokenisation changes how a stake is recorded and transferred — not the underlying asset, the risk, or the eligibility rules.
FADP — Swiss data residency
The revised Swiss Federal Act on Data Protection (FADP) governs the processing of personal data. OwnMore is built for Swiss-resident data handling (Swiss / EU infrastructure), with processors under data-processing agreements.
How OwnMore operationalises this frame
OwnMore sets no thresholds and gives no advice. It encodes the frames as order: eligibility (FinSA) and KYC (GwG) before disclosure of an opportunity; every action sealed into a SHA-256 audit chain; data under the FADP. Honest on maturity: automated AML screening in preparation, KYC manual, connection to FINMA-supervised custody being onboarded, audit chain at block #00001. OwnMore makes no one legally compliant and replaces neither the legal determination nor SRO affiliation; OwnMore is pre-launch.