Employer (bank) restricting the use of other brokers

Helix · June 15, 2026, 2:50pm

As far as I know, it is not. The FINMA states in “Circular 2013/8 Market conduct rules”

D. Surveillance of employee transactions

53 Supervised institutions must take measures for the surveillance of employee transactions. These measures must in particular be capable of preventing employees from misusing insider information in transactions for their own account and of identifying such misuse. Due attention must be paid to all custody accounts and related cash accounts held by employees with the supervised institution or a third-party institution as well as those for which employees have beneficial ownership or power of attorney.

54 For the purpose of these rules, employees are defined as all members of the supervised institution’s staff, together with the members of governing bodies responsible for directing, supervising and controlling, the executive management, partners with unlimited liability and anyone with a comparable function.

55 Supervised institutions must set out their appropriate and suitable surveillance measures in an internal directive. Different levels of surveillance may be applied to different categories of employees or functions in line with the risk of misuse of insider information. Regardless of such risk categories, supervised institutions must ensure that they can access information on all relevant cash and custody accounts whenever necessary.

There is no requirement for custody. Especially, since the board is often exempt from the made up custody requirements (because they would bolt rather than suffer such rules).

Also compare for the conflict of such internal regulations with Art. 323b Abs. 3 OR also known as “Truckverbot” (ban on truck systems) which voids agreements that use salaries to the benefit of the employer. See my post: