Actively Managed Certificates (AMCs) in Swiss Wealth Management

Actively Managed Certificates (AMCs) are among the most flexible tools in Swiss private banking and independent wealth management. In essence, they let an asset manager run a discretionary strategy inside a single, tradable security. Because each AMC carries an ISIN, it offers daily liquidity, position-level transparency, and easy booking across most bank platforms. Moreover, one certificate can hold equities, bonds, funds, options, or other structured products. As a result, Actively Managed Certificates suit thematic, tactical, and multi-asset strategies.

Swiss banks and independent asset managers (IAMs) also use Actively Managed Certificates to deliver tailored mandates without launching a full fund. In short, AMCs cut setup costs and shorten time-to-market. In addition, they are available on most private-bank platforms, which makes them practical and scalable for almost any investor mandate.

What Is an Actively Managed Certificate (AMC)?

An AMC is a structured note issued by a bank or a dedicated issuance platform. Specifically, it tracks a discretionary strategy run by a named asset manager. Unlike a passive index product, however, the portfolio is adjusted regularly. The manager trades within clearly defined rules, and as a result the certificate mirrors the live portfolio in close to real time.

The note is issued under Swiss or international law, and the strategy is documented through factsheets and term sheets. In practice, most AMCs in private banking are placed privately with professional and qualified investors rather than offered to the public.

The Legal Framework for Actively Managed Certificates in Switzerland

Under Swiss law, an Actively Managed Certificate is treated as a structured product, not a collective investment scheme. This distinction matters. As a result, AMCs fall outside the Collective Investment Schemes Act (CISA / KAG) and are not subject to FINMA product approval or ongoing fund supervision. Instead, the conduct rules of the Financial Services Act (FinSA / FIDLEG) and its ordinance (FinSO / FIDLEV) apply at the point of sale.

How AMCs Are Offered to Investors

Two practical consequences follow. First, because there is no fund wrapper, the investor carries the issuer’s credit risk and does not benefit from the specific protection that CISA gives fund holders. Second, the distribution rules depend on the client type:

• Retail clients: the producer must publish a Key Information Document (KID) under Art. 58 FinSA. In addition, a prospectus may be required, although for structured products it can be reviewed after publication.
• Issuer requirement: structured products may be offered to retail clients only if they are issued, guaranteed, or equivalently secured by a supervised institution — namely a bank, an insurer, or a securities firm — or via a special purpose vehicle under defined conditions (Art. 70 FinSA).
• Professional investors: private placements need adequate documentation but no Swiss registration. For this reason, most private-banking AMCs follow this route.

Finally, the asset manager running the strategy may itself need a licence under the Financial Institutions Act (FinIA) and supervision by FINMA. That said, this information is general in nature and is not legal or tax advice; therefore, structures should always be reviewed case by case.

Why Use Actively Managed Certificates in Swiss Portfolios?

• Flexible content: combine several asset types in one product
• Speed: launch and adjust strategies quickly
• Bankability: available via ISIN on most private-bank platforms
• Transparency: position-level reporting and regular updates
• Thematic focus: access to niche sectors, ESG, or regional ideas

In practice, Actively Managed Certificates fit well into tactical mandates and overlay structures. Notably, they allow fast reallocation and usually carry no upfront entry load. Therefore, for the active investor or wealth manager, that combination is hard to match with a traditional fund format.

Risks Associated with Actively Managed Certificates

Of course, AMCs also carry risks that every investor should weigh carefully:

• Issuer risk: investors depend on the creditworthiness of the issuer
• Liquidity limits: daily trading depends on the liquidity of the underlying assets
• Complexity: a strategy can be hard to assess if it is not clearly disclosed
• Fee layers: management, performance, and structuring costs can stack up
• Less product protection: as structured products, AMCs lack the CISA safeguards that apply to funds

AMCs vs Other Investment Formats

The table below compares Actively Managed Certificates with two common alternatives. In particular, note the difference in regulatory regime and setup time.

Aspect	AMC	UCITS Fund	Structured Product
Management style	Active (discretionary)	Active or passive	Fixed return pattern
Customisation	High	Low to medium	Medium
Setup time	2–6 weeks	3–9 months	Quick
Regulatory regime	FinSA (structured product)	CISA (fund)	FinSA (structured product)
Tradable	Yes (ISIN)	Yes	Yes
Daily liquidity	Usually	Yes	Sometimes

Who Uses Actively Managed Certificates?

• IAMs running bespoke strategies
• Private banks scaling house views
• HNWI and UHNWI with specific investment themes
• Advisors designing flexible mandates

Most Swiss AMCs are custom-built and white-labelled. As a result, portfolio managers can scale a strategy across markets without the cost of a full fund. Often, the choice comes down to the independent manager versus the bank — and to which one can deliver the strategy faster and at lower cost for the investor.

Independent Platforms: The GenTwo Model

Beyond banks, platforms such as GenTwo open a new route to issuing AMCs. In short, GenTwo lets IAMs and family offices launch their own certificates — branded, compliant, and bankable — without drawing on a bank’s balance sheet. Moreover, its setup reaches non-bankable assets such as real estate, private equity, or digital assets, and turns them into economically bankable instruments that sit in a normal custody account via ISIN.

This model gives the manager control over content, pricing, and compliance. In addition, it reduces reliance on a single institution at a time when access to banking relationships in Switzerland can no longer be taken for granted. In practice, it lets Swiss wealth managers bring institutional-grade products to the investor on their own terms.

Example AMC Allocation

In a CHF 10 million portfolio, for example, a manager might allocate 10% to Actively Managed Certificates:

• 4% ESG equity AMC
• 3% multi-asset yield AMC
• 2% innovation-focused AMC (via GenTwo)
• 1% lower-risk fixed income AMC

Overall, this adds thematic exposure while keeping liquidity and oversight intact. Furthermore, it works comfortably inside traditional custody environments.

Frequently Asked Questions About AMCs

Are Actively Managed Certificates regulated in Switzerland?

Yes, but as structured products under the Financial Services Act (FinSA), rather than as funds. As a result, they are not approved by FINMA at product level, so investor protections differ from those of a collective investment scheme.

What is the main risk of an AMC?

Above all, issuer credit risk. Because an AMC is a note rather than a fund, its value depends on the issuer’s ability to meet its obligations, in addition to the performance of the underlying strategy.

Do AMCs offer daily liquidity to the investor?

Usually. However, the actual liquidity depends on the underlying assets held in the strategy.

Can an independent wealth manager issue its own AMC?

Yes. For example, through issuance platforms such as GenTwo, IAMs and family offices can launch their own bankable certificates without using a bank’s balance sheet.

Conclusion

Actively Managed Certificates (AMCs) have become a core building block in Swiss wealth management. Above all, they combine flexibility, transparency, and speed in a single bankable security. Whether issued by a private bank or a platform like GenTwo, they let a manager turn a strategic idea into a tradable product. That said, every investor should keep the issuer risk and structured-product nature in mind. Overall, with ISIN access and daily liquidity, Actively Managed Certificates bridge bespoke thinking and bankable solutions.

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