Interim legal and compliance for banks and financial institutions

Short answer: Banks and financial institutions mainly use interim legal and compliance professionals for KYC remediation, AML and transaction monitoring backlogs, sanctions screening, regulatory change projects, product and master agreement documentation, and to cover vacancies in legal and compliance. Typical roles are KYC analysts and compliance officers in taskforces, interim compliance officers, regulatory project lawyers and banking and capital markets legal counsel. Responsibility for meeting the obligations always stays with the institution; in Germany, Section 6(7) sentence 4 of the Anti-Money Laundering Act (GwG) says so expressly.

This guide is for heads of legal, heads of compliance, MLROs and COOs at banks, asset managers and fintechs in Switzerland and Germany. It shows which interim roles fit which compliance projects in banking, what supervision and confidentiality require, and how a KYC team is set up in practice.

Which interim roles do banks need? Project type, role and seniority

The right role follows from the type of project. The table shows the most common combinations in banks and financial institutions.

Alpinum Solutions provides these roles through staff leasing or freelancing, part-time or full-time, as individuals or as a taskforce. Banking, financial services and fintech is one of the sectors in which Alpinum has completed assignments over the last 24 months.

Legal: product documentation, master agreements and capital markets

Bank legal teams mainly need interim support when many contracts must be updated at once or a transaction is coming up. Typical tasks:

• Repapering: updating master agreements, client documentation and general terms after legal or product changes.
• Product documentation: reviewing key information documents, product terms and sales material.
• Service provider and ICT contracts: aligning outsourcing and IT contracts with supervisory rules, such as Section 25b of the German Banking Act (KWG) or FINMA Circular 2018/3 "Outsourcing" in Switzerland.
• Capital markets: issuance documentation, due diligence, support for the instructed law firm.

Relevant profiles are described under banking, finance and capital markets law.

Compliance: KYC, AML, sanctions and regulatory change

Compliance projects in banks are high-volume and deadline-driven. That is why they are the most common reason for interim teams.

KYC and periodic review

KYC remediation brings client files up to date: identification, beneficial owner, source of wealth, risk rating. The guide on planning KYC remediation with interim specialists covers staffing and process. The same guide shows how Swiss banks then plan periodic reviews of client relationships as business as usual.

AML and transaction monitoring

Alert backlogs build up after rule changes, system migrations or audit findings. Interim analysts work alerts against fixed instructions and escalate suspicious cases to in-house compliance.

Sanctions

New sanctions packages create short-notice screening work on clients, payments and business partners. The EU adopted its 21st sanctions package against Russia on 23 July 2026. Switzerland does not adopt EU sanctions automatically but decides on each package individually under the Embargo Act; the listings of the 21st package have applied there since 11 August 2026. Switzerland had not adopted a further listings-only package of 12 October 2026 as at 31 October 2026. Financial intermediaries freeze assets of listed persons and report affected business relationships to SECO. This report replaces neither the clarifications under Art. 6 GwG nor a report to MROS, the Swiss financial intelligence unit, under Art. 9 GwG.

Regulatory change

New rules have to be translated into directives, processes and controls. Examples from the regulatory calendar:

• DORA: has applied to EU financial entities since 17 January 2025 (Art. 64 DORA). In Switzerland, FINMA Circular 2023/1 on operational resilience has had to be fully implemented since its transitional periods ended on 1 January 2026.
• Swiss AML revision and transparency register: in force since 1 October 2026. Financial intermediaries report discrepancies with the transparency register from 1 April 2027 (Art. 30, 54 TJPG). FINMA Guidance 04/2026 sets out expectations for the money laundering risk analysis under Art. 25(2) of the FINMA AML Ordinance.
• AMLR (EU): the single EU anti-money laundering rulebook applies directly in all member states, including Germany, from 10 July 2027. From 2028 the EU authority AMLA in Frankfurt will directly supervise up to 40 cross-border financial institutions.

The guide on DORA legal and compliance workstreams also covers what FINMA expects in Switzerland.

Supervision in Switzerland and Germany: what applies when using external professionals

In both countries, supervisors require the institution to keep control over tasks that are outsourced or supported externally. The details differ.

A staff leasing assignment is generally not outsourcing but additional staff working under the institution's direction. In Germany, the institution decides and documents whether a specific arrangement is outsourcing under MaRisk AT 9 or section 6(7) GwG (BaFin guidance, section 3.10). In Switzerland, outsourcing under FINMA Circular 2018/3 requires a provider to perform a significant function independently and on a permanent basis, whereas a leased professional works under the host company's instructions (Art. 26 AVV). Under staff leasing the institution holds the right to give professional instructions and the professional is integrated into its organisation; under freelancing the professional works independently within the agreed mandate.

Profiles, languages and confidentiality

Good interim profiles for banks combine subject expertise with experience of the institution's systems and processes. These criteria help with selection:

• Specialism: KYC/AML, sanctions, regulatory, banking law or capital markets; not every compliance professional fits every topic.
• Type of institution: experience at a private bank, universal bank, cantonal bank, asset manager or fintech shapes working style and risk awareness.
• Systems: familiarity with common KYC, screening and monitoring tools shortens onboarding.
• Languages: depend on the client book and working environment; state in the role profile which languages are needed to negotiation level.
• Confidentiality: confidentiality agreement, personal log-ins, work on the institution's devices, no data on private devices.

See the guide on confidentiality and access for interim staff.

Example: KYC taskforce with eight compliance officers

In 2025 a financial institution in Switzerland deployed a taskforce of 8 FTE: compliance officers including a team lead, each at 100 %, through staff leasing. The work covered KYC remediation, KYC file reviews, transaction monitoring, alert handling and documentation. The team lead reported to in-house compliance. Selected profiles were available within 48 hours; the team started around two weeks after the order was placed. The project was completed in 10 months. Details are in the case study KYC taskforce with eight compliance officers.

Limits and risks

• Responsibility stays with the institution: decisions on client relationships, reports to the financial intelligence unit and risk ratings are made by the institution.
• Formal functions: professionals can take on formal functions such as a compliance officer with regulatory responsibility. For the money laundering reporting officer (MLRO), regulatory requirements may rule out an external mandate or require staff leasing. This needs clarifying before the start.
• No legal advice from Alpinum: Alpinum is not a law firm; legal opinions and representation stay with law firms.
• Quality at volume: without four-eyes checks, sampling and clear work instructions, files end up inconsistent and internal audit will raise findings.

Frequently asked questions about interim compliance in banking

Can external professionals access client data?

Yes, provided the institution controls access and safeguards confidentiality and data protection. Usual measures are a confidentiality agreement, personal and time-limited log-ins, work on the institution's devices and systems, and logging. In Switzerland banking secrecy applies; in both countries the outsourcing rules must be considered. The institution makes the assessment with its compliance function.

How quickly can a KYC team be set up?

At Alpinum, selected profiles are usually available within 48 hours; the institution and Alpinum agree the start date together. The time until the team is productive depends mainly on onboarding: access rights, system training and work instructions. In the KYC taskforce from the case study, the team started around two weeks after the order was placed.

Staff leasing or freelancing for compliance in banks?

Taskforces that are closely tied into the institution's processes, systems and reporting lines often use staff leasing. Freelancing fits better for clearly defined mandates with independent work, such as an opinion on a directive or leading a workstream. Both models are available part-time or full-time.

What seniority does a KYC project need?

A KYC project usually needs a mix: junior and experienced analysts for file work, experienced compliance officers for high-risk clients and escalations, and a senior team lead for steering, quality and reporting. The ratio depends on the share of high-risk clients and on the quality of the starting data.

Can interim professionals act as a compliance officer with formal responsibility?

Yes, professionals can take on formal functions such as a compliance officer with regulatory responsibility, through staff leasing or freelancing. Whether that is permissible in a given case depends on the institution's requirements and the rules in Switzerland or Germany. Statutory independence and responsibilities remain intact.

Next step

Tell us about the project type, volume, languages and deadlines. We will show you suitable profiles or a taskforce set-up for your institution.

• Banking, finance and capital markets law
• AML and KYC remediation
• Interim compliance officer: tasks, requirements and engagement models
• Discuss your requirements

Last updated: 31 October 2026.