Compliance & FINMA
FINMA compliance is not a project. It is a permanent condition.
What FINMA expects in concrete terms and what this means in technical terms.
The relevant principles for IT security at FINMA-regulated institutions are FINMA Circular 2023/1 (Operational risks and resilience) and RS 2008/21 for banks. The new supervisory regime under FinIA and FinSA has applied to asset managers and trustees since 2020, which also sets out specific requirements for operational security.
The requirements can be summarized in four areas: Firstly, access and authorization controls, i.e. who is allowed to access which systems and data, verifiably and with minimal rights. Secondly, monitoring and logging, i.e. all security-relevant events are recorded, stored and can be analyzed. Thirdly, business continuity and incident management, which means defined processes for emergencies, tested and documented. Fourthly, supplier management, i.e. proof that external service providers also meet the requirements.
We translate these requirements into concrete technical architectures based on Microsoft 365 and Microsoft Azure that fulfill these points structurally, not just on paper.
Least privilege is not a recommendation. It is a requirement for FINMA-regulated institutions.
The principle of minimum authorization means that each user receives exactly the rights they need for their task, and no more. Privileged access such as admin rights are not assigned permanently, but are only activated via Privileged Identity Management (PIM) on request, for a limited time and with a complete audit trail.
The same applies to external service providers, including us at Dinotronic: access to your environment is exclusively via GDAP (Granular Delegated Admin Privileges), role-based, time-limited and logged. You can see who has accessed what and when at any time.
This structure is not an additional measure for the audit, but the normal mode of operation. What is operated in this way on a daily basis can also be verified on a daily basis.
A security incident is not the problem. Not dealing with it in a documented way is.
FINMA expects security incidents to be recognized, reported and processed. This requires three things: complete logging of all security-relevant events, a defined incident response procedure and the ability to reconstruct exactly what happened afterwards.
Microsoft Sentinel takes over the central logging and correlation of events from all connected systems: Identities, end devices, cloud services, network. Anomalies are automatically detected and prioritized. Our security team evaluates these signals 24/7 and initiates the incident response process if necessary.
Every incident is documented in writing: Time, affected systems, impact, measures, conclusion. This documentation is stored in an audit-proof manner and is available for audits on request. Not compiled when the audit comes, but kept on an ongoing basis.
Who opened, changed or passed on which file and when?
Supervised institutions are responsible for the security of their data, even if it is held by an external provider. FINMA Circular 2023/1 is explicit: outsourcing does not release institutions from their responsibility. The service provider must meet the requirements and the institution must be able to prove this.
As an ISO 27001-certified Microsoft Solutions Partner, we structurally fulfill these requirements. Our certification is not a one-off, but is confirmed annually by an independent audit. Microsoft Azure and Microsoft 365 operate under a joint responsibility model that clearly defines which security responsibilities lie with Microsoft and which with us.
On request, we can provide you with the necessary evidence for your own supplier management: ISO certificate, processing directory, subcontractor overview and other documents to complete your compliance documentation.
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“The cooperation with Dinotronic was excellent from the first contact to the end of the project and I can wholeheartedly recommend the product to any company of any size.”
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