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Banque Cantonale Vaudoise (BCV)

Banque Cantonale Vaudoise is a Swiss cantonal bank headquartered in Lausanne and established by law as a public-law institution. Its published mission and service network are clearly focused on residents of the canton of Vaud and local businesses. BCV states that its standard business current account is for small and medium-sized enterprises and large companies, but eligibility of non-resident/overseas applicants, complete account-opening requirements, and the scope of remote processing for individuals or businesses must still be confirmed in writing by the bank.

Regulator
Swiss Financial Market Supervisory Authority (FINMA)
Check date
2026-10-26
Verify status
Some information remains to be confirmed: BCV's legal entity information, the specific entity row in FINMA's official list of authorised banks for that day, BCV's corporate current account products and Swiss AML/tax/sanctions baselines have been checked. Complete eligibility and documents for personal accounts, acceptance of non-residents and overseas businesses, remote witnessing, account-opening fees/timelines/minimum balances and the scope of FINMA authorisation still require case-specific confirmation from the bank or regulator.

Research scope and official resources

Topic number:europe-banque-cantonale-vaudoise

selection.json lists this entity among selected large Swiss banks using the Tier 1 capital measure in The Banker Top 1000 World Banks 2026. This is selection context for publicly listed large institutions in 2025/2026, and does not represent BCV’s individual rank, a real-time top 100, current account application acceptance, or a licensing conclusion.

Bank’s official website

Personal Eligibility and Documents

BCV publicly describes personal day-to-day banking services and account products and emphasizes local service in the Canton of Vaud. However, as of the verification date, the official pages that could be accessed did not clearly set out complete eligibility rules for general personal accounts concerning Swiss residents, non-residents, foreign nationals or applicants with an overseas address. Nor could the applicable online account-opening age, country/region restrictions or remote identity-verification conditions be verified. Swiss residents may ask BCV about the relevant products and application methods. Whether people living abroad are accepted, and the applicable account, tax-residence conditions and process, all require written confirmation from BCV and should not be treated as approved.

Personal information publicly disclosed or identified

  • A complete list of documents for a BCV personal account could not be confirmed from the official pages that were accessible. General preparation suggestions (not a policy published by BCV or a guaranteed list for acceptance): prepare a valid passport or identity document and, where applicable, a Swiss residence permit. In line with Swiss AML identity-verification and CRS/AEOI information-reporting rules, you may also prepare proof of residential address, a tax-residence self-certification and relevant tax identification number (TIN), and provide a source-of-funds explanation if requested by the bank. The regulatory baseline for identity and beneficial-owner checks is set out in s7; CRS/AEOI exchange fields are set out in s8.
  • If applying for a specific BCV product, such as a rental deposit account, its account structure differs from that of a general current account. Do not assume that the application documents or purposes for this product apply to all personal accounts. The product page states that the account is jointly held by the tenant and landlord and frozen during the lease term; see s6.

Company eligibility and documents

BCV’s official Corporate current account page expressly describes the product as a basic corporate account for small and medium-sized businesses and large companies, for company banking transactions (including foreign-currency transactions) and use of BCV-net. The page does not confirm eligibility rules for foreign-incorporated companies, non-Swiss places of business, specific industries, foreign shareholders or beneficial-owner structures, nor does it publish complete corporate account eligibility criteria or review documents. Whether a foreign legal entity may apply must be confirmed in writing with BCV.

Company information publicly disclosed or identified

  • BCV’s corporate account page does not list a complete set of account-opening documents. General preparation suggestions (not a policy published by BCV or a guaranteed list for acceptance): company registration/commercial registration and organizational documents, signatory authorization or board resolution, identity documents for signatories and ultimate beneficial owners, an ownership/control-structure description, and tax-residence information and applicable TINs for the company and beneficial owners. BCV must confirm the specific formats, certification/translation requirements and document validity periods. Swiss AML rules address the identity of contracting parties, identification of the beneficial owners of assets, and checks into the background of unusual transactions; see s7. CRS/AEOI fields are set out in s8.
  • To prepare for possible due diligence, you may generally prepare information on the business purpose, expected transactions, source of funds/wealth and supporting documents. This is preparation advice for complying with Swiss banks’ AML due diligence, not a published, fixed BCV-specific checklist or a condition guaranteeing approval; see s7.

Address, tax, and remote / witnessed procedures

Address and tax

The city listed as the address in BCV’s legal bank records is Lausanne. Public information does not confirm the requirements for an applicant’s residential address, company registration address, or actual business address, or whether BCV accepts addresses outside Switzerland. Switzerland’s official AEOI information lists details that may be exchanged, including account holders’ names, addresses, countries of tax residence, and tax identification numbers. Individuals and companies should provide relevant tax-residency declarations and applicable TINs based on their actual tax-residency status. Whether BCV requires a particular format, a Swiss address, or a tax number must be confirmed by the bank for the specific application; a company UID should not be assumed to be equivalent to an individual’s or entity’s tax TIN.

Remote / witnessing

BCV says it can provide personal or business banking advice to customers by video call. This confirms only that a consultation channel exists; it does not establish that accounts can be opened remotely worldwide, remote identity verification can be completed, third-party witnessing is accepted, or documents may be signed online. BCV’s public materials do not confirm acceptable witnesses, certified or notarized documents, or a remote account-opening arrangement for applicants abroad. These must all be confirmed in writing by the bank based on the applicant’s location.

Public process reference

  1. First distinguish whether the applicant is an individual or a business, and confirm the intended product. BCV publicly lists personal account categories and a company Corporate current account product (s4、s5).
  2. Contact BCV through its official contact/branch channels to ask whether it accepts applicants based on their nationality, tax residence, actual residence or company registration location, and ownership/control structure. BCV mentions branch appointments and video consultations, but a video consultation does not mean remote account opening or verification (s4).
  3. Before submitting, request from BCV the official checklist of documents, tax declarations, fees, and signing methods applicable to this product and the applicant’s location. The website does not publicly confirm the complete steps for opening a general personal account or eligibility rules for companies registered overseas.
  4. If the bank confirms that it will accept the application, submit identity/business and beneficial-owner information, a source-of-funds explanation and tax-residency information using the method it specifies, then wait for the bank to complete due diligence and make an acceptance decision. This is a preparatory step in the context of Swiss AML/AEOI compliance, not a BCV commitment regarding an approval process or timeframe. The processing sequence, whether an in-person visit is required and the activation time must all be confirmed with the bank (s7, s8 ).

Compliance topics, details, and sources

Swiss anti-money laundering and customer identity verification (AMLA/KYC)

Switzerland’s Anti-Money Laundering Act applies to financial intermediaries; FINMA explains that it supervises compliance with AMLA by prudentially supervised banks. Banks must verify the identities of contracting parties and investigate the background and purpose of unusual or high-risk business relationships/transactions, and report to MROS when necessary. This statutory baseline does not mean BCV has publicly disclosed a fixed document checklist for specific individuals or companies.

Beneficial owners, control relationships, and source of funds

The Swiss banking due diligence baseline includes identifying the beneficial owner of assets. In unusual cases, where there are indications of criminal funds, or in high-risk situations, further inquiries into the background of funds/transactions and the purpose of the business relationship are also required. Corporate applicants should truthfully disclose control and beneficial owner information and provide evidence of the source of funds as requested by the bank. Specific thresholds and BCV-specific document requirements have not been publicly confirmed.

Swiss CRS/AEOI tax-residency reporting

Switzerland has implemented the automatic exchange of financial account information. The Swiss Federal Tax Administration lists the information exchanged as including name, address, country of tax residence, tax identification number, account balance and capital income. Tax residency status and the applicable TIN should be provided truthfully. Partner jurisdictions and the specific scope of application are determined under Swiss rules and according to the account holder’s actual tax residence; submitting tax information should not be mistaken for a guarantee that an account will be opened.

U.S. Persons and FATCA (Separate from CRS)

The Swiss Federal Tax Administration explains that Switzerland has a separate FATCA cooperation arrangement with the United States. Current information describes the relevant reporting/administrative assistance by Swiss financial institutions concerning U.S. accounts. The reciprocal Model 1 agreement signed in 2024 was, according to the status on that official page, still being prepared for implementation, with entry into force planned no earlier than 2029. U.S.-related reporting should be checked separately under FATCA; it must not be stated that the United States has joined CRS. BCV has not publicly confirmed its specific account-opening or documentation policies for U.S. persons.

Swiss sanctions screening

Swiss SECO provides an official search tool and consolidated list of sanctioned individuals, companies, and organizations; its search tool shows only directly sanctioned parties and does not provide ownership or control information. Applicants and parties connected to the funds must comply with applicable Swiss sanctions rules; BCV’s specific screening systems, risk standards, and individual case outcomes have not been made public, and a search that returns no match should not be taken to mean that the bank will necessarily accept the application.

Swiss personal data protection

Switzerland’s revised Federal Act on Data Protection entered into force on 2023-09-01, applies to the processing of personal data, and assigns supervisory functions to the Federal Data Protection and Information Commissioner. During an application, BCV may process identity, address, and tax-related information; specific purposes, retention periods, and cross-border transfer arrangements should be determined from BCV’s privacy documentation and applicable law. This file does not make assumptions about its internal practices.

Compliance evidence

Account-opening compliance and supporting-document checklist

The bank’s stated requirements, local regulations, and preparation recommendations are presented separately. Acceptance in a specific case is subject to confirmation by the bank.

BCV’s public Corporate current account is aimed at small and medium-sized businesses and large companies, with services including business transactions and BCV-net. The public page does not confirm eligibility for foreign-incorporated companies, non-resident individuals or specific industries. The following are key preparations for corporate account opening; individual applicants should first confirm the applicable product and eligibility with BCV, and this should not be treated as acceptance. If assistance is engaged, Mr. Tang can follow up personally on documents and appointments, explain fees in advance and confirm timing; no bank outcome is guaranteed.

Date information checked:2026-10-26

Information evidence package

Company identity, authorized representatives, and business activities

Who it applies to
Companies intending to apply for a BCV business current account; the businesses to which the bank's published product applies are not thereby confirmed as eligible if registered overseas.
Documents to Prepare
  • Prepare the company’s registry extract, articles of association, and registered/business address information, and explain its place of incorporation, main business, and account purpose.
  • Prepare a resolution authorizing the account or signatories, and identification and contact details for the authorized signatories.
  • Generally, prepare recent contracts, invoices, or a business description, as well as the expected countries, currencies, counterparties, and amount ranges for incoming and outgoing payments. These are suggestions to help explain the business, not a fixed checklist published by BCV.
Description
The BCV page states that this account serves business transactions, includes foreign-currency transactions, and can be used with BCV-net, but does not list complete account-opening documents, certification or translation methods, or document validity periods. First request a list from the bank for this applicant; do not assume in advance that notarization is required or that scanned documents are accepted.

Ownership chain, controllers, and actual beneficial owners of assets

Who it applies to
Companies, partnerships and their shareholders/controllers; confirm with BCV based on the specific legal form and applicable exceptions.
Documents to Prepare
  • Map the ownership and control chain from the applicant entity to the ultimate natural persons, specifying ownership percentages, voting rights and other means of control.
  • Prepare registration documents for each tier, the shareholder register/organizational chart, and proof of identity, names and residential addresses for the relevant controllers and beneficial owners.
  • If the structure involves multiple layers, nominees, a trust, or control that is not reflected by ownership percentages, prepare explanatory documents and the corresponding legal documents for the bank to assess.
Description
CDB 20 provisions on identifying controllers of operating entities/partnerships, generally including persons holding at least 25% of shares or voting rights. If no such person exists, identify another ascertainable controller; if none can be determined, identify the senior manager instead. This threshold is not a global rule and does not replace a separate declaration of the beneficial owner of assets. BCV should confirm the specific forms and types of evidence.

Personal identity and tax residency information

Who it applies to
Company signatories, controllers, and beneficial owners; individual applicants should first confirm whether BCV accepts applicants from their place of residence and their application method.
Documents to Prepare
  • Prepare a valid passport/identity document and accurate residential address information as instructed by the bank; prepare a residence permit only where applicable.
  • Organize the tax residence, applicable tax identification number (TIN), and information required for tax self-certification for yourself and related entities.
  • For cross-border income or complex tax residence circumstances, prepare a brief factual explanation and have a tax adviser verify it before submission.
Description
Information exchanged under Swiss AEOI includes names, addresses, country of tax residence, tax identification numbers, account balances, and capital income; this demonstrates the importance of tax information, but does not establish BCV’s specific forms, address deadlines, or account-opening eligibility.

Due diligence and enhanced verification

Counterparty identity and company controllers

Basis for Verification
FINMA explains the framework applicable to banks for identity verification and beneficial owner identification under CDB 20. Article 20 of CDB 20 concerns operating legal entities/partnerships and provides for identifying persons who control 25% or more of voting rights/equity, as well as alternative provisions for other forms of control and for management. Its scope is subject to specific entity types and exceptions.
Preparation recommendation
Submit an organizational chart and explain shareholders, voting rights, and actual control at each tier. Identify any tiers for which information cannot be obtained, the reasons, and any alternative evidence; do not provide only a list of direct shareholders.
Scope
CDB 20 banking due diligence code; it should not be described as a generally applicable Swiss statutory 25% threshold or as a complete list of documents published by BCV.

Declaration of beneficial ownership of assets

Basis for Verification
Article 27 of CDB 20 requires banks to obtain a declaration of the beneficial owner of assets; account opening is one applicable situation. Article 28 requires relevant identity information to be recorded when a third party is declared to be the beneficial owner. The code also has a Form A requirement and specific exceptions when an individual establishes a relationship by correspondence.
Preparation recommendation
Confirm the actual ownership and beneficial arrangements for the account funds, and prepare beneficiary information and evidence of source of funds. If the company itself is the beneficiary of the funds or a third-party arrangement exists, disclose this accurately and ask BCV which declaration form applies.
Scope
Specific due diligence rules under CDB 20; do not conflate identification of company controllers with a declaration of the beneficial owner of account assets. BCV's own forms and required copy authentication methods have not been publicly confirmed.

Unusual business, PEPs, and high-risk relationships

Basis for Verification
FINMA explains that when a transaction is unusual, funds are suspected to be proceeds of crime, or a relationship involves a high-risk country or a politically exposed person (PEP), financial intermediaries must further establish the financial background and purpose of the relationship or transaction. High-risk relationships require more detailed records and clarification. PEP status does not automatically mean an application will be rejected.
Preparation recommendation
It is advisable to prepare the source-of-wealth/funds chain and supporting evidence, such as business income, audited financial statements, contracts, or asset sale or inheritance documents. If PEPs, related parties, or high-risk jurisdictions are involved, explain the role, relationship, flow of funds, and mitigating factors.
Scope
Swiss regulatory due diligence baseline; BCV’s risk appetite, internal limits, specific enhanced-review thresholds and conclusions have not been made public and should not be inferred.

Cross-Border Tax Residence and Tax Identification Number Reporting

Basis for Verification
Under the Swiss AEOI framework, reporting financial institutions collect and exchange account identification, tax residence, TIN, and account/financial information; applicability depends on the account holder’s actual tax status and Swiss rules.
Preparation recommendation
Check the tax residence and TIN of the entity and each relevant individual, ensuring that the self-certification matches the company registration, address, and actual business information. For multiple tax residencies or no TIN, first confirm with BCV how to explain this.
Scope
The Swiss Federal Tax Administration’s AEOI/CRS information-exchange baseline; this is not a complete list of account-opening approval conditions and does not support inferences about specific exchange partner countries or BCV’s internal reporting procedures.

Ongoing maintenance obligations

Update customer and control information promptly

If the company's ownership, control, signing authority, address, or tax residency information changes, it is advisable to notify BCV promptly and update supporting evidence as required. CDB 20 requires relevant due diligence on identity, controllers, and beneficiaries to be repeated when questions arise; the published code and BCV product page do not specify a fixed annual review frequency applicable to all customers.

Keep transactions explainable in relation to the business originally declared

Keep contracts, invoices, shipping/delivery or payroll and tax records to explain counterparties, amounts, countries and source of funds. If a transaction clearly deviates from the stated business, the rules described by FINMA require the bank to clarify its background and purpose; BCV's specific trigger criteria and customer response deadlines are not public.

Statements and account monitoring

BCV’s corporate account page lists quarterly statements by default and says daily, weekly or monthly statement/notification options can be selected. After opening the account, check transactions and promptly report any questions to the bank; the page does not describe the statement frequency as a regulatory requirement or AML review frequency.

Please confirm with the bank before booking

  1. Does BCV accept the applicant’s place of incorporation, place of actual business, place of residence, and tax residence? Are there restrictions by industry or country?
  2. For this legal form and ownership chain, which controllers and beneficial owners must be disclosed to the bank? Does it use Form A, Form K or its own BCV forms?
  3. Must extracts from the register, articles of association, authorization resolutions, and identity documents be originals or certified copies, or are electronic documents accepted? Is certification or translation required, and how is document validity calculated?
  4. What evidence is required for source of funds/wealth, expected transactions, and cross-border transactions? Are supplementary documents required where PEPs, related parties, or multi-tier ownership are involved?
  5. Can identity verification and signing be completed remotely? If so, which countries are eligible, what witnessing/certification methods apply, and is in-person attendance required?
  6. What are the fees for opening and maintaining an account and for cross-border services, the minimum balance, estimated review time, procedures for notifying the bank of information changes, and review arrangements?

Not confirmed by public information

  • The public pages reviewed do not confirm whether non-resident individuals or companies registered/operating overseas can open accounts, or which countries, regions, and industries are accepted.
  • BCV has not publicly confirmed a complete list of personal/corporate documents, standards for originals or certified copies, translation requirements, document validity periods or specific beneficial-owner forms.
  • Remote identity verification, signing/witnessing overseas, account-opening review times, fees, and minimum balances must all be confirmed in writing on a case-by-case basis. A BCV video consultation is not a commitment to open an account remotely.
  • BCV’s internal risk standards and acceptance limits for PEPs, specific jurisdictions, complex ownership structures, or particular business activities are not public and should not be invented.
  • The frequency of periodic reviews and the specific channels/deadlines for customers to proactively update information have not been confirmed from the materials reviewed; check with the bank.

Sources & Scope of Verification

  1. BCV — Corporate current account

    BCV states that this account is intended for SMEs and large companies, supports business and foreign-currency transactions, and provides access to BCV-net. It lists quarterly statements, optional statement frequencies, and some fees; it does not provide a complete eligibility or document list for opening an account.

  2. FINMA — Combating money laundering

    FINMA explains its anti-money laundering supervisory responsibilities, the CDB 20 framework for banks’ identity and beneficial owner checks, and the need for further clarification of the background and purpose of unusual or high-risk relationships, PEPs and other matters; it does not disclose individual client standards of BCV.

  3. Swiss Bankers Association — Agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence, CDB 20

    The relevant provisions of the official CDB 20 PDF have been reviewed: Article 20 on the 25% rule for controlling persons of operating entities and substitution based on control method/management; Articles 27–28 on declarations of the actual beneficiaries of assets; Article 45 on the deadline for completing documents; and Article 46 on repeating due diligence when doubts arise. The code contains scope limitations and exceptions and is not a global rule or a publicly available BCV application checklist.

  4. Swiss Federal Tax Administration — Exchange of information with 101 countries on around 3.4 million financial accounts

    The Swiss Federal Tax Administration describes the account identification and financial information exchanged under AEOI/CRS, including name, address, country of tax residence, tax identification number, balance and capital income. The stated number of partner countries reflects the time when the page was reported and is not cited as a permanent list.

Fees and timelines

Limited record of company account charges published on the BCV Corporate current account page only: the page states that BCV-net transactions in CHF within Switzerland are free of charge; each BCV-top QR bill costs CHF 1; the first 3 counter withdrawals per quarter are free, with each subsequent withdrawal costing CHF 5; each payment instruction costs CHF 25; other fees are subject to the company account terms. The page states that the relevant fee document was last updated on 2026-07-01. These are CHF amounts disclosed on that product page at the time, not a complete schedule of all service fees. Personal account opening fees, business account opening fees, minimum deposits/balances, approval/opening times, and additional fees for non-residents have not been confirmed in public materials.

Limitations and practical considerations

  • BCV’s statutory mission, branches, and public descriptions of its business mainly focus on local communities and companies in Vaud. This does not constitute a public commitment to accept residents of other countries or regions, or companies incorporated abroad.
  • Eligibility for non-resident individuals and foreign companies to open accounts, permitted countries of residence/registration, industry restrictions, minimum balance and any additional due diligence requirements have not been publicly confirmed; request a written response from BCV first.
  • Public pages provide online entry points for personal accounts and applications for business accounts, but the content available for review is insufficient to verify the eligible age range, fully online identity verification, global remote processing, or third-party witnessing. Video consultations are not evidence of an account-opening witnessing service.
  • This public information does not indicate that BCV has an appointment-based account-opening channel for specific customers or that it is a currently bookable channel through Rengangyongsheng (Hong Kong) Limited. It must not be used to promise customers that an account will be accepted or approved.

Licensing evidence and regulatory verification

A specific record for Banque Cantonale Vaudoise was found in FINMA’s official “Authorised banks and securities firms” list: Lausanne, authorisation category shown as Bank, and category 3 in the list row. The official PDF metadata generation date is 2026-10-26. The list entry does not give a separate licence number or the specific scope of retail business authorisation. FINMA’s directory states that the list is updated regularly and that the list alone cannot guarantee that there have been no changes in authorisation status. Accordingly, this confirms the entity’s presence in the official list on that date; it does not guarantee the full scope of business permissions or any applicant’s eligibility to open an account. If necessary, confirm with FINMA or the bank.

Swiss Financial Market Supervisory Authority (FINMA) Official registration or record

Information sources

  1. BCV 2024 Annual Report

    BCV’s annual report states that Banque Cantonale Vaudoise was established by the Vaud Cantonal Parliament as a bank constituted under public law, and discloses its relationship with its cantonal shareholder, legal status, and regional mission. This is used to confirm the legal entity, not to establish specific account-opening eligibility or the status of a 2026 license.

  2. FINMA — Authorised banks and securities firms, official list generated 26 October 2026

    Download and read the specific entry in the official FINMA PDF: Banque Cantonale Vaudoise, Lausanne, license category Bank, list category 3. The PDF metadata generation date is 2026-10-26. The entry does not show a license number or specific product authorization scope.

  3. FINMA — Authorised institutions, individuals and products

    FINMA explains that its list of authorized institutions is updated periodically and cautions that an institution may have been authorized but not yet listed, or may have lost its authorization while still appearing on the list. This limits what the s2 list can establish and provides a regulatory lookup resource.

  4. BCV — About the bank

    BCV states that it has branches in Vaud and serves local residents and businesses, offers personal and business banking advice and video consultations, and lists personal day-to-day banking and account products. The page does not establish that video consultations can replace remote account-opening verification.

  5. BCV — Corporate current account

    BCV states that its standard business current account is for SMEs and large companies, describes the product’s features, BCV-net, interest rates, and fees, and identifies the update date of the relevant fee document as 2026-07-01. It does not confirm eligibility for foreign legal entities or provide a complete account-opening document list.

  6. BCV — Security deposit account

    BCV describes a specific rental deposit account as jointly held by the tenant and landlord and frozen during the lease term, and explains the relationship between the deposit and the lease. This supports only the structure of that dedicated product and should not be generalized to ordinary personal accounts.

  7. FINMA — Combating money laundering

    FINMA explains the due diligence and disclosure obligations of financial intermediaries under the Swiss AMLA, the identification of banks and beneficial owners, checks into the background of unusual/high-risk transactions, and the suspicious transaction reporting mechanism.

  8. Swiss Federal Tax Administration — Exchange of information with 101 countries on around 3.4 million financial accounts

    The Swiss Federal Tax Administration describes AEOI/CRS implementation and the fields that may be exchanged for account holders, including name, address, country of tax residence, tax identification number, balance and capital income. The stated number of countries reflects the status in the year reported on that page and is not a permanent list.

  9. Swiss Federal Tax Administration — Administrative assistance in accordance with FATCA

    Information on the FATCA agreement between Switzerland and the United States and on U.S. account reporting/administrative assistance, noting that the reciprocal Model 1 agreement signed in 2024 is still being implemented and is planned to take effect no earlier than 2029-01-01; intended to distinguish it from CRS, not to prove BCV’s acceptance policy for U.S. persons.

  10. SECO — Searching for subjects of sanctions and overall list

    Swiss SECO official sanctions-list search and entry point for the combined XML list, with an express statement that its search tool shows only directly sanctioned parties and does not show possible ownership or control relationships.

  11. Swiss Federal Data Protection and Information Commissioner — New FDPIC’s role

    The Swiss Federal Data Protection and Information Commissioner describes the revised Federal Act on Data Protection as having entered into force on 2023-09-01 and outlines its supervisory responsibilities. This supports the general legal baseline for personal data protection in Switzerland; it does not describe BCV’s specific internal processing practices.