Interim legal and compliance in asset management: funds, distribution and supervision

Short answer: Asset managers bring in interim legal counsel or compliance professionals when fund launches, marketing notifications, licence applications or outsourcing exceed in-house capacity. In Switzerland, fund management companies and managers of collective assets need a FINMA licence (Art. 5(1) FinIA); in Germany, investment management companies need BaFin authorisation (section 20(1) KAGB). Responsibility stays with the institution.

This guide is for general counsel, heads of compliance and COOs at fund management companies, managers of collective assets, portfolio managers and German investment management companies (KVGs). It covers the typical uses of interim legal counsel in asset management, which profiles fit which work, and how FINMA and BaFin supervision differ.

When asset managers need extra capacity

Asset managers are supervised at two levels in both countries: the institution and, depending on the product, the fund itself. FINMA explicitly describes this as dual supervision of institution and product for funds that require approval. That creates peaks the in-house team rarely handles alone:

• Fund launch or product change: fund contract, investment terms, prospectus and key information documents must be drafted, updated and filed with the supervisor.
• Marketing in new countries or to new investor groups: marketing notifications, distribution documents and distribution agreements.
• Licence, change or restructuring: a new licence, material organisational changes, new executives or a group reorganisation.
• Outsourcing and service providers: portfolio management, administration or IT is outsourced or retendered, and contracts and notifications fall due.
• Vacancy or absence: if the fund legal counsel or the head of compliance is out, projects and ongoing controls stall at the same time.

Six steps to set up the assignment

An interim assignment in asset management delivers quickly when the trigger, deadlines and scope are fixed before day one.

1. Record the trigger and deadline: fund launch, marketing notification, licence or change application, outsourcing, audit finding or vacancy, with the date owed to the supervisor, depositary or distribution partners.
2. Define the scope: what stays with the in-house team, what the interim professional takes on and what goes to a law firm or the auditor.
3. Set the profile: fund or distribution law, compliance, product type (securities, real estate, private markets), country, level and workload (20–100 %).
4. Choose the engagement model: staff leasing when the professional works in your team, in your systems and under your direction; freelancing for a defined package such as reworking a set of fund documents.
5. Settle access and confidentiality: personal user accounts, a confidentiality agreement, company devices, and rules on inside information and personal account dealing.
6. Plan the handover: file templates, checklists, supervisor correspondence and open points so the team can carry on after the assignment.

Checklist: typical workstreams and matching profiles

The table maps typical asset management workstreams to profile and level.

Alpinum Solutions provides lawyers and compliance professionals for banking, finance and capital markets law through staff leasing or freelancing, as individuals or teams, part-time or full-time. Banking, financial services & fintech is one of the sectors in which Alpinum has supported assignments over the last 24 months.

Roles and capacity

Support ranges from one professional working part-time to a full project team. Three questions help with planning:

• How much is design and how much is execution? New structures, licence applications and interpretation questions need senior experience; updating documents, controls and files is often work for experienced or junior professionals.
• How fixed are the dates? If a launch or marketing start depends on a filing, staff the project lead and the documentation work separately.
• Which interfaces matter? Fund legal works closely with portfolio management, risk, the depositary, fund administration and distribution. Experience with these interfaces shortens onboarding.

In our experience, experienced is the most common level for interim assignments. Selected profiles are usually available within 48 hours; the start date is agreed between the institution and Alpinum. For the wider picture across banks and financial institutions, see Interim legal and compliance for banks and financial institutions.

Switzerland and Germany: what differs

The work is similar in both countries. Laws, licences and procedures differ.

In Austria, assignments run as freelancing or as staff leasing through the German or the Swiss company.

Limits and risks

• Responsibility stays with the institution: applications, notifications, fund documents and distribution decisions are owned by the executive board and the relevant functions of the institution.
• No legal advice from Alpinum: Alpinum is not a law firm. Legal opinions, structuring advice and representation before the supervisor stay with the institution or an external law firm.
• Check for outsourcing: whether an assignment counts as outsourcing and must be notified is assessed and documented by the institution itself.
• Conflicts and inside information: interim professionals see portfolios, transactions and investor data. Rules on personal account dealing and confidentiality apply from day one.
• Steering by model: in staff leasing, the institution directs the work; in freelancing, the professional works independently within the agreed mandate.

Frequently asked questions on interim legal counsel in asset management

What do asset managers use an interim legal counsel for?

Typical triggers are fund launches and product changes, marketing notifications and distribution documents, licence and change applications, new outsourcing and service agreements, and vacancies in the legal team. The interim legal counsel works inside the team and the institution's systems. Legal opinions, structuring questions and representation before the supervisor remain with a law firm.

What experience should a fund legal counsel bring?

What matters is fund law in the right country, experience with the product type, such as securities funds, real estate funds or private markets, and familiarity with the processes involving the supervisor, depositary and fund administration. Senior experience makes sense for licences and new structures; experienced profiles often suit documentation and distribution work. Test experience at interview against specific projects.

How does supervision differ between Switzerland and Germany?

In Switzerland, FINMA licenses fund management companies, managers of collective assets and portfolio managers under FinIA and approves the documents of funds requiring approval under CISA; portfolio managers are supervised on an ongoing basis by a supervisory organisation. In Germany, BaFin authorises KVGs under the KAGB and runs the marketing notification and outsourcing procedures.

Staff leasing or freelancing in asset management?

Staff leasing fits when the professional is closely tied into the institution's reporting lines, processes and systems, for example to cover a vacancy or ongoing compliance. Freelancing fits defined packages such as reworking fund documents or preparing a marketing notification. Both models work part-time or full-time, for individuals or teams.

How quickly can a professional start?

Selected profiles are usually available within 48 hours; the start date is agreed between the institution and Alpinum. Time to productive work depends mainly on access rights, confidentiality rules and onboarding. Plan the support as soon as a filing or marketing date is fixed.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in Switzerland and Germany. Tell us about the trigger, deadlines and profile, and we will send selected profiles for staff leasing or freelancing.

• Banking, finance and capital markets law: interim lawyers for financial institutions
• Interim legal and compliance for banks and financial institutions
• Roles & practice areas: all guides on roles and practice areas
• Discuss your needs

Last updated: 10 November 2026.