Overview
- Average Client Assets
- $15.9 million
- Minimum Account Size
- $3,000,000
- SEC CRD Number
- 292433
Fee Structure
Primary Fee Schedule (JSSAMNA- FORM-ADV-PART-2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.00% |
Minimum Annual Fee: $20,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
- HNW Share of Firm Assets
- 73.53%
- Total Client Accounts
- 225
- Discretionary Accounts
- 100
- Non-Discretionary Accounts
- 125
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
Primary Brochure: JSSAMNA- FORM-ADV-PART-2A (2026-03-25)
View Document Text
Firm Brochure / Form ADV Part 2A
J. Safra Sarasin Asset Management
(North America) Ltd
March 18, 2026
Firm Brochure / Form ADV Part 2A
We will provide you annually with a copy of our updated
Brochure or a summary of material changes from the
Brochure previously provided to you. In addition, you may
also obtain a copy of our current Brochure at any time free
of charge via the above-mentioned telephone number or e-
mail address.
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 10
Item 2: Material Changes
There have been no material changes to the Brochure since
its last annual update and filing on March 21, 2025.
J. Safra Sarasin Asset Management (North America) Ltd,
Zurich Branch
Alfred Escher Strasse 50
CH-8022 Zurich
Switzerland
Tel. +41 (0)58 317 64 00
www.jsafrasarasin.com/northamerica
SEC no.: 801-112502
IARD/CRD no.: 292433
Item 1: Cover Page
in
This Form ADV Part 2A disclosure brochure (the “Brochure”)
provides information about the qualifications and business
practices of J. Safra Sarasin Asset Management (North
America) Ltd (“JSSAMNA”, “us” or “we”). If you have any
questions about the contents of this Brochure, please
(0)58 317 64 00 and/or
contact us at +41
this
information
jssamna@jsafrasarasin.com. The
Brochure has not been approved or verified by the United
States Securities and Exchange Commission (the “SEC”) or
by any state securities authority.
Additional information about us is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Please note that registration with the SEC as a registered
investment adviser does not imply a certain level of skill or
training.
The information in this Brochure is current as of the date
indicated above and is subject to change at our discretion.
1
Firm Brochure | Form ADV Part 2A | March 18, 2026
Table of Contents
Item 1: Cover Page
1
Item 2: Material Changes
1
Item 3: Table of Contents
2
Item 4: Advisory Business
3
Item 5: Fees and Compensation
4
Item 6: Performance-Based Fees and Side-by-Side Management
4
Item 7: Types of Clients
5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
5
Item 9: Disciplinary Information
7
Item 10: Other Financial Industry Activities and Affiliations
7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
9
Item 12: Brokerage Practices
10
Item 13: Review of Accounts
11
Item 14: Client Referrals and Other Compensation
11
Item 15: Custody
11
Item 16: Investment Discretion
11
Item 17: Voting Client Securities (Proxy Voting)
12
Item 18: Financial Information
12
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Firm Brochure | Form ADV Part 2A | March 18, 2026
Item 4: Advisory Business
investments
with JSSAMNA. Under a Discretionary Mandate, we will
manage your assets on a fully discretionary basis in line
with the agreed investment strategy, taking into account
your investment profile and objectives. We will be solely
responsible for defining the asset allocation, making the
underlying
in your discretionary portfolio
covered by the Discretionary Mandate and periodically
review and adjust the discretionary portfolio in response to
economic, political or market conditions.
About J. Safra Sarasin Asset Management (North America)
Ltd (“JSSAMNA”, “us” or “we”)
JSSAMNA is a corporation organized under the laws of
Switzerland with its head office and main place of business
in Geneva, Switzerland, and a branch
in Zurich,
Switzerland, which was established in September 2024.
We provide
investment advisory services mainly to
individuals, trusts, estates, charitable organizations and
small corporations or similar small business entities
residing in, or organized under the laws of, the United
States of America (the “US”). JSSAMNA may, in certain
limited cases, also advise other clients, such as US citizens
residing outside the US.
We allow investment restrictions such as those related to
specific securities, certain types of securities or industries.
Any such restrictions imposed by you on our Discretionary
Mandate may cause the selected investment strategy to
differ in performance and risk profile from the unmodified
mandate developed by our investment team, which may be
used by other clients of JSSAMNA.
We are a wholly owned subsidiary of J. Safra Sarasin
Holding Ltd, Basel, Switzerland (“JSSH”). JSSH is ultimately
owned and controlled by members of the Joseph Y. Safra
family.
Investment Advisory Agreement
Please refer to the supplement of this Brochure (ADV Form
Part 2B) to learn more about JSSAMNA’s key personnel.
Advisory mandate
If you wish to have your assets managed on a non-
into a Non-
discretionary basis, you must enter
Discretionary
(the
“Advisory Mandate”) with JSSAMNA. Under the Advisory
Mandate, we will provide you with our investment views and
recommendations upon request and in accordance with
your investment profile and objectives. We may also
periodically contact you and offer recommendations that
we consider suitable and appropriate for you.
About our investment advisory services
We specialize in tailored investment advisory services to
high net worth clients and offer both discretionary asset
management services as well as non-discretionary
investment advisory services. In doing so, we will make
recommendations based on your investment profile and
objectives.
In contrast to the Discretionary Mandate, you will be solely
responsible for making all investment decisions and we will
not have any discretionary authority over your assets. We
will furthermore not provide continuous and regular
supervision of your non-discretionary portfolio covered by
the Advisory Mandate and will not be responsible for pro-
actively updating any previous investment views and
recommendations in response to economic, political or
market conditions.
Our investment advisory services may cover a variety of
asset classes in US and international markets, including
cash in various currencies, equity and debt securities,
mutual funds, fiduciary deposits, certain derivatives and
(physical) precious metals. Depending on your investment
profile and objectives, we may also consider other types of
investments.
We are not registered as a broker-dealer with the SEC or
any other US or non-US regulatory authority. Accordingly,
we do not provide any brokerage services.
For Advisory Mandates, we generally do not permit any
investment restrictions as any restrictions in your non-
discretionary portfolio would be self-imposed and
controlled by you.
Discretionary mandate
If you wish to have your assets managed on a discretionary
basis, you must enter
into a Discretionary Asset
Management Agreement (the “Discretionary Mandate”)
Assets under management
As of end of December 2025, we provided investment
advisory services for USD 934’502 million in assets under
in
management, of which USD 523’957 million are
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Firm Brochure | Form ADV Part 2A | March 18, 2026
Discretionary Mandates and USD 407’985 million are in
Advisory Mandates.
Item 5: Fees and Compensation
or Advisory Mandate. With respect to the charging of the
Advisory Fee, we will discuss and agree on the debiting
arrangement for the Advisory Fee with you and the non-
affiliated custodian bank.
trade settlement,
foreign
Advisory Fee
For our investment advisory services, we are compensated
on the basis of an investment advisory fee (the “Advisory
Fee”) calculated at the end of each calendar quarter (31
March, 30 June, 30 September, 31 December) as a
percentage of the entire assets (including cash) held in the
client account(s) of the custodian bank that are covered by
either the Discretionary Mandate or Advisory Mandate.
For our Discretionary Mandate and Advisory Mandate, the
Advisory Fee is an annual rate of 1% of your entire assets
(including cash) in the mandate, subject to a minimum
quarterly Advisory Fee of CHF 5,000.
We reserve the right to waive, discount, increase or
otherwise negotiate our Advisory Fees.
Other expenses
Our Advisory Fees do not include custodian bank fees, fees
currency exchange
for
transactions, brokerage commissions, wire transfer or any
other fees or taxes (e.g. value added tax, Swiss stamp duty)
imposed by the custodian bank, broker-dealers or other
service providers. Our Advisory Fees also do not include any
management or other fees charged by funds or issuers of
other financial instruments you may be invested in.
Depending on the services you request from the custodian
bank or other service providers, you may additionally be
charged for special services such as US tax reporting or
reclaiming of withholding taxes. All these fees will reduce
the overall return of the investment advisory portfolio(s)
covered by either the Discretionary Mandate or Advisory
Mandate.
Management fees to affiliates
If we or you invest in collective investment vehicles and
similar products managed by an affiliate of JSSAMNA, that
affiliate may be economically benefited through the receipt
of a management fee for such products. We will not share
such fees.
No other compensation
We do not accept any compensation for any sale of any
financial instruments, referral of prospective clients or have
any other type of revenue-sharing arrangement with
another party unless disclosed otherwise. In addition, we
do also not charge any transaction-based fees or fees for
transmitting orders to broker-dealers for execution.
Item 6: Performance-Based Fees and Side-by-Side
Management
Calculation and charging of the Advisory Fee
If Bank J. Safra Sarasin Ltd in Basel, Switzerland (“BJSS”),
or another affiliate of JSSAMNA selected by you (together
with BJSS the “Affiliated Custodian”), acts as custodian
bank, the Advisory Fee will be calculated in Swiss francs
based on the Affiliated Custodian’s market valuation of all
of the assets (including cash) held in the client account(s)
with the Affiliated Custodian that are covered by either the
Discretionary Mandate or Advisory Mandate at the end of
each calendar month during the quarter for which the
Advisory Fee is charged. The Advisory Fee will be charged in
arrears at the end of the quarter in Swiss francs to your
client account(s) with the Affiliated Custodian. In case the
Discretionary Mandate or Advisory Mandate is terminated,
the Advisory Fee for the entire last calendar month is
charged in full. If your client account(s) with the Affiliated
Custodian does not hold enough Swiss francs, then the
debiting of the Advisory Fee will result in a foreign exchange
transaction. The Affiliated Custodian will be compensated
for effecting such a foreign exchange transaction.
We do not charge performance-based fees.
In case of a non-affiliated custodian bank, the Advisory Fee
will generally also be calculated by such custodian bank’s
market valuation of all of the assets (including cash) held in
the account(s) with the selected non-affiliated custodian
bank that are covered by either the Discretionary Mandate
Our policies and procedures aim to ensure that investment
advisory portfolios are treated fairly and equitably over
time. Any investment decisions for such portfolios are
made with specific reference to the individual investment
profile and objective of each client. We may therefore give
4
Firm Brochure | Form ADV Part 2A | March 18, 2026
time and may change your risk tolerance, investment
profile and objective as well as the investment strategy
selected by you.
-
investment advice or exercise investment responsibility or
take other actions for clients that may differ from the advice
given, or the timing and nature of actions taken, for other
clients. Investment results for different portfolios, including
portfolios that are generally managed in a similar style, may
also differ as a result of these considerations. Some clients
may not participate at all in some investments in which
other clients participate, or may participate to a different
degree or at a different time.
-
Item 7: Types of Clients
-
As specified under Item 4, we provide investment advisory
services to mainly high net worth individuals, trusts,
estates, charitable organizations and small corporations or
similar business entities who are residing in the US, or
organized under US laws. We may, in certain limited cases,
also advise other clients.
A fixed income or defensive investment strategy may
allow you to seek a modest level of losses and returns,
while accepting low risk and low fluctuation to your
initial principal. These strategies may not generate
significant income and may not keep pace with
inflation.
A dynamic or an equity investment strategy may allow
you to maximize returns over time, but require you to
accept a very high level or risk and fluctuation to your
initial principal. Investors in these strategies may lose
most or all of the initial principal invested.
In between, a balanced investment strategy may
expose your initial principal to moderate risk and
return expectation. However, all or a portion of your
initial principal could still be lost.
We consider that a minimum Discretionary Mandate or
Advisory Mandate value of USD 3,000,000 allows for most
efficient management and sufficient diversification.
Investment advisory mandates with smaller values may be
accepted based on specific circumstances and we may
aggregate investment advisory mandates that have family,
corporate or other relationships at our discretion.
if
It is of highest importance that we apply sound methods of
analysis and investment strategy to your investment
investment team periodically
advisory mandate. Our
organizes an investment committee, where investment
views are formulated and translated into asset allocation
decisions. We take into consideration economic, political
and market factors, such as gross domestic product,
inflation, short and long-term interest rates. The asset
allocation decisions may impact each risk profile and their
related investment strategies.
We reserve the right to terminate your participation in a
Discretionary Mandate or Advisory Mandate
the
investment amount falls below the minimum value as
described above. Under normal circumstances, we will not
do so if such decrease in value is attributable to the
performance of your Discretionary Mandate and/or
Advisory Mandate.
Item 8: Methods of Analysis, Investment Strategies and
Risk of Loss
Our investment strategies and advice involve financial
instruments with varying risk degrees, from lower risk (e.g.
cash and high-quality debt securities) to higher risk
investments (e.g. equity securities). Currency allocation,
country exposure and sector weighting are key elements,
which may substantially alter the risk of any strategy. We
generally allocate a higher portion of low risk financial
instruments to conservative strategies, while growth
strategies will be more exposed to riskier financial
instruments.
Broadly speaking, we tend to invest in companies with
strong balance sheets, stable earnings and efficient
management. We avoid micro-cap securities, unstable
countries, leveraged investments and businesses that we
do not understand. We do not engage in “day trading”,
Our investment team defines several investment strategies
that are appropriate to different degrees of risk. All
investments carry a risk of loss. The investment strategy
you select must reflect the risk of loss you are willing to
bear. The higher the expected returns you may have, the
greater the risk you could lose. We consider various factors
to select what we believe to be the most suitable
investment strategy for you. These factors could evolve over
5
Firm Brochure | Form ADV Part 2A | March 18, 2026
-
“high frequency trading” or any other form of excessive
trading.
We regularly monitor your Discretionary Mandate and
usually review its asset allocation, typically on a monthly
basis, but not less frequently than quarterly. We may
engage in more financial instrument transactions on behalf
of clients during any particular quarter depending on
market conditions or changes in client investment strategy.
than
Generally speaking, all investments are subject to a risk of
financial loss that you should be prepared to bear. You
must understand the factors that can potentially lead to
such loss. Examples of common risk types may include,
without limitation:
-
factors,
such
as
-
-
-
-
-
-
- Market risk: prices in any investment can go up and
rapidly and unpredictably, caused by
down
macroeconomic
economic
developments, changes in interest rates, political
changes, and other catastrophic events (e.g. war,
terrorism, climate change, pandemics and public
health issues);
Interest rate risk: debt securities can fluctuate in
value as interest rates change. Central banks may
change interest rates at various times during the
business cycle, which may affect corporate debt’s
income and performance. Also, debt securities with
longer maturity will typically be more sensitive to
changes in interest rates compared to similar ones
with a shorter maturity;
is associated with the
Credit risk: credit risk
uncertainty in an issuer's ability to meet its obligation
to pay interest and/or principal, or even go bankrupt
(sometimes referred to as solvency risk);
Liquidity risk: due to low trading volume, you could be
exposed to the risk of not being able to sell, or buy, a
specific financial instrument. This generally happens
with companies having a small market capitalization
or debt security during period of stress; for instance,
debt securities rated below investment grade, also
called “high yield bonds”, offer better yield, but are
generally more volatile and less liquid than other debt
securities;
Foreign exchange risk or currency risk: this risk
generally arises from the change in value of one
currency against another. Currency exchange rates
can be extremely volatile, especially during times of
political or economic unrest, or as a result of actions
taken by central banks. The risk depends on which
level your
investment advisory portfolio will be
allocated to your reference currency versus another;
Foreign/Emerging markets risk: foreign/emerging
markets are affected by global economic factors and
generally do not have the level of market efficiency
and strict standards in accounting and securities
in developed countries. Some
regulation
foreign/emerging markets may also have less trading
volume, which may make it more difficult to sell a
financial
instrument. You must understand that
investing in foreign/emerging markets come with
much greater risk due to political instability, domestic
problems and currency volatility and may trigger
larger and more frequent price changes in the short
term; and
Concentration risk: we usually describe concentration
risk when the allocation to a market segment or a
company is higher than others. This could be related
to a country, a company, an industry or any specific
financial instruments invested. The concentration risk
may lead to an increased risk (or opportunity) for
additional loss (or profit).
Equity securities risk: equity securities represent an
ownership interest in an issuer rather than a right to
receive a specified future payment. This makes equity
securities more sensitive than fixed income or debt
investments to changes in an issuer’s earnings and
overall financial condition; as a result, equity
securities are generally more volatile than fixed
income or debt investments. Equity securities may
lose value as a result of changes relating to the
issuers of those securities, such as management
performance, financial leverage, or changes in the
actual or anticipated earnings of a company, or as a
result of actual or perceived market conditions that
are not specific to an issuer. Even when the securities
markets are generally performing strongly, there can
be no assurance that equity securities will increase in
value. Because the rights of all of a company’s
creditors are senior to those of holders of equity
securities, shareholders are least likely to receive any
value if an issuer files for bankruptcy.
Debt securities risk: investments in fixed income or
debt securities are subject to the risk of an issuer’s
ability to meet principal and interest payments on the
obligation (credit risk), price volatility due to interest
the
rate
sensitivity, market
perception
of
6
Firm Brochure | Form ADV Part 2A | March 18, 2026
international business activity generally, or in any of
the countries or jurisdictions in which investments are
located. Additionally, a major
governmental
intervention into industry, including but not limited to
the nationalization of an industry or the assertion of
control over an investment, could result in a loss to a
client. Any of the foregoing would therefore adversely
affect the performance of investments.
Item 9: Disciplinary Information
-
As of the date of this Brochure, there is no disciplinary
information to report.
Item 10: Other Financial Industry Activities and Affiliations
-
General comment
As described under Item 4, JSSAMNA is a wholly owned
subsidiary of JSSH. JSSH also owns BJSS, a Swiss bank
licensed and supervised by the Swiss Financial Market
Supervisory Authority FINMA with its principal office in
Basel, Switzerland. BJSS provides banking and investment
services for private and institutional clients in Switzerland
and abroad. Neither JSSH nor BJSS are registered with the
SEC as a broker-dealer or investment adviser or with any
other US regulatory authority. As part of the JSSH Group,
JSSAMNA is subject to the consolidated supervision of the
JSSH Group.
While JSSAMNA and other entities of the JSSH Group do not
share any staff, our Chairman also serves as director
and/or executive manager of BJSS and other entities of the
JSSH Group.
creditworthiness of the
issuer, general market
liquidity (market risk) and potential inability to access
additional financing due, e.g. to high leverage. The
price of a debt instrument generally moves inversely
with interest rates, such that a rise in interest rates
typically causes a fall in value, while a fall in interest
rates typically causes a rise in value. The risk of debt
securities can vary significantly depending upon
factors such as the credit quality of the issuer and the
maturity of the instrument. For example, the issuer of
a security or the counterparty to a contract may could
default or otherwise become unable to honor a
financial obligation, resulting in losses.
Inflation risk: inflation and rapid fluctuations in
inflation rates have had in the past, and could in the
future have, negative effects on the economies and
financial markets, which may in turn affect the
markets in which a strategy or client invests. For
example, wages and prices of inputs increase during
periods of inflation, which can negatively impact
returns on investments. Governmental efforts to curb
inflation often have negative effects on the level of
economic activity. There can be no assurance that
inflation will not become a serious problem in the
future and have an adverse
impact on an
investment’s returns.
Risks related to force majeure events: there is a risk
that investments could be impacted by force majeure
events (i.e. events beyond the control of the party
claiming that the event has occurred, such as acts of
God, war, warlike events, civil unrest, instructions and
sanctions by government, terrorism, accidents, labor
strikes, energy blackouts, communication failures,
outbreaks of an infectious disease, pandemic or any
other serious public health concern, or other
unavoidable objective circumstances such as forces
of nature, including bad weather, earthquake, fire,
flood, atmospheric effects, magnetic fields and
similar circumstances). There is a risk that some force
majeure events will adversely affect the ability of a
party (including an investment, a counterparty of such
investment or a counterparty of client) to perform its
obligations until it is able to remedy the force majeure
event. Such a party could also claim force majeure for
nonperformance of
its contractual obligations.
Certain force majeure events (such as an outbreak of
an infectious disease, e.g. COVID-19) could have a
broader negative impact on the world economy and
In line with Swiss legal and regulatory requirements,
JSSAMNA is since December 2024 authorized as a portfolio
manager by the Swiss Financial Market Supervisory
Authority FINMA and affiliated with AOOS – Schweizerische
Aktiengesellschaft für Aufsicht (a Swiss company limited by
shares for supervision), a Swiss supervisory organization
(SO) and self-regulatory organization (SRO) duly recognized
and approved by FINMA. Whilst the SO supervises
JSSAMNA’s conduct as a portfolio manager, the SRO
assumes a supervisory role in the context of combating
money laundering and the financing of terrorism as per
applicable Swiss law.
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Firm Brochure | Form ADV Part 2A | March 18, 2026
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JSSAMNA is furthermore affiliated with the Swiss Banking
Ombudsman. In case of a dispute with JSSAMNA, you may
approach the Swiss Banking Ombudsman, Bahnhofplatz 9,
P.O. Box, 8021 Zurich (www.bankingombudsman.ch). The
Ombudsman deals with specific complaints which are
raised against banks and other financial services providers
such as portfolio managers based in Switzerland. He is
independent and neutral and he treats inquiries strictly
confidential. The mediation process is free of charge.
-
Material relationships with affiliated entities
There are various
forms of arrangements between
JSSAMNA and its affiliates as described further below,
some of which inherently involve material conflicts of
interest. Before utilizing the services described below, you
should understand these arrangements and the conflicts
they pose. While we generally believe that BJSS and other
affiliates identified below provide services of comparable
quality and, to the extent applicable, at comparable prices
to other market participants, we do not independently
evaluate, and we do not represent, whether that is or
remains the case. Furthermore, JSSAMNA requires its
affiliates to limit the use of any information to the purpose
for which it was provided and to keep them confidential in
accordance with applicable laws and regulations. More
details are available in our Data Privacy Statement.
rates between and among
-
-
recommended
-
In addition,
Custody and banking services: you may select BJSS or
one of certain other affiliates of JSSAMNA as
custodian bank for assets covered by our investment
advisory services. Depending on your country of
residence and the Affiliated Custodian, you may
obtain limited complementary banking services from
the Affiliated Custodian as permitted under the local
requirements in your home jurisdiction. The fees for
the Affiliated Custodian’s services may be more or
less favorable than those that may be obtained from
non-affiliated third-parties. We are not party to any of
the Affiliated Custodian’s services and do not receive
compensation in relation to these arrangements.
While our Advisory Fees will be deducted directly from
your account(s) with the Affiliated Custodian, we do
not have custody of your assets. You will furthermore
for your
receive periodic account statements
the
from
investment advisory portfolio directly
Affiliated Custodian.
the Affiliated
Custodian may charge fees for effecting foreign
exchange transactions or other services, which are
charged in addition to any custodial fees.
Execution services: for your investment advisory
portfolio, JSSAMNA will, consistent with our duty of
best execution, route securities orders to either Safra
Securities LLC (“Safra Securities”), an affiliate that is
registered as a broker-dealer with the SEC and a
member of the US Financial Industry Regulatory
Authority (FINRA) or other broker-dealers as disclosed
further in Item 12 below. Fees charged to JSSAMNA
by Safra Securities will be passed through and
charged to you except for brokerage commissions
that may be charged for certain non-US securities by
third party brokers used by Safra Securities that will
be charged to you directly as part of the purchase
price of the security. The fees for Safra Securities’
services may be more or less favorable than those
that may be obtained from non-affiliated third-parties.
We do not receive compensation in relation to this
arrangement.
in
investments
Cash/Currency accounts: cash
various currencies
investment advisory
in your
portfolio are held with the Affiliated Custodian as
custodian bank and you are therefore exposed to the
credit risk of the Affiliated Custodian. Moreover, if you
in multiple
hold cash or assets denominated
fluctuating
currencies, you will be exposed to
exchange
those
currencies.
Fiduciary deposits: unless instructed otherwise by
you, fiduciary deposit investments in your investment
advisory portfolio will be placed via the Affiliated
Custodian in their own name, but at your risk with the
Affiliated Custodian’s
fiduciary
counterparties at the point of time of the investment.
The fiduciary counterparties are generally affiliates of
the Affiliated Custodian and such placements are
therefore exposed to the credit risk of such affiliates
as well as the Affiliated Custodian itself. We, and the
Affiliated Custodian, have a financial incentive to
make such fiduciary deposit investments with such
affiliates.
Derivatives: over-the-counter derivative investments
in your investment advisory portfolio such as foreign
exchange forwards will be placed with the Affiliated
Custodian and you are therefore exposed to the credit
risk of
the Affiliated Custodian. The Affiliated
Custodian charges fees in connection with such
8
Firm Brochure | Form ADV Part 2A | March 18, 2026
-
-
employees, reflect our fiduciary obligations to act in your
best interest, and addresses prevention of any conflict of
interest associated with the personal trading activities of
our employees and certain members of their families. All of
them must periodically submit specific reports which reflect
their current personal securities holdings, as well as their
most recent securities transactions. Our Chief Compliance
Officer reviews these reports on a regular basis and
ensures our employees or certain members of their families
do not take inappropriate advantage of their positions in
relation to your investment advisory portfolio.
We also have policies and procedures that are designed to
prevent the misuse of material and non-public information
which may become available to us via you or other means.
Our employees are prohibited from using such information
for you, their benefit or the benefit of third parties.
-
Any employee who fails to respect the provisions of the
Code of Ethics can be subject to sanctions, which may
include verbal warnings, suspension of personal trading
rights, disgorgement of profits and, in most severe cases,
the possibility of dismissal or to be reported to the relevant
authorities.
-
We can provide you with a copy of our Code of Ethics upon
request.
transactions, and accordingly we have a conflict of
interest in selecting the Affiliated Custodian.
Precious metals: precious metal investments in your
investment advisory portfolio are held with the
Affiliated Custodian as custodian bank. In case that
precious metal investments are not held in physical
form, you are exposed to the credit risk of the Affiliated
Custodian.
Research and joint investment meetings: in addition
to research obtained by non-affiliated entities,
JSSAMNA may obtain research reports prepared by
BJSS and participate in periodic investment meetings
in order to share macroeconomic views, asset
allocation and investment ideas. We are not required
to follow or agree with these views and ideas of BJSS,
and our investment team has the discretion to take
positions for your investment advisory portfolio that
deviate from the ones taken by BJSS.
Shared premises: JSSAMNA and BJSS are located in
the same building and we share office space and
common areas. However, our own workspace and
documents storage room stay physically segregated
from those of BJSS and any information related to
current, former and prospective clients are kept
confidential. Appropriate access controls are
enforced to comply with this rule.
Corporate support services: BJSS provides various
support services that are generally unrelated to our
investment advisory services to you such as facility
management, IT and telephone infrastructure, human
legal
resources, mailing services, controlling or
support.
Relationships with unaffiliated entities
Instead of an Affiliated Custodian, you may select a non-
affiliated custodian bank to provide custodial and other
services. If you select a non-affiliated custodian bank, we
will work with this custodian bank to ensure that you
receive periodic account statements for your investment
advisory portfolio directly from the custodian bank.
Affiliate/Related person transactions
As described under Item 4, JSSAMNA is a wholly owned
subsidiary of JSSH and thus part of the JSSH Group. Certain
affiliates and related persons of JSSAMNA such as BJSS
may from time to time invests in securities that are also
recommended by JSSAMNA to
its clients. However,
information barriers and other restrictions (including
separate trading systems and staff) are in place between
JSSAMNA and such affiliates/related persons, such that
neither party is aware of, nor has access to, the investment
advisory recommendations or trades of the other affiliated
entity made on behalf of its respective clients.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
We have adopted a Code of Ethics which sets forth
standards of business conduct that apply to all our
9
Firm Brochure | Form ADV Part 2A | March 18, 2026
Item 12: Brokerage Practices
Research and other soft dollar benefits
We did not select Safra Securities and Baird, and will
generally not in the future select any other broker-dealer,
for securities transactions based upon a soft commission
or soft dollar arrangement.
Broker-dealer selection
We have an obligation to seek “best execution” for client
transactions. Best execution generally refers to the
execution of transactions in such a manner that the total
costs or proceeds in each transaction are the most
favorable under the circumstances. The SEC defines best
execution as “best qualitative execution” and not merely
the lowest possible execution cost. When evaluating the
quality of execution provided by our selected broker-
dealers, we will review the following factors:
-
We receive third party research via Safra Securities as well
as proprietary research prepared by Baird and BJSS,
including periodically and publically available newsletters
as well as access to their research platform. These
materials are provided to us free of charge, i.e. do not result
in a different level of commissions or fees charged, and not
subject any transaction volume directed to a particular
broker-dealer. We do not consider the provision of research
or other services when evaluating execution services.
-
On the broker-dealer’s side: financial strength,
markets coverage, settlement efficiency, quality of
communication, level of commission vs. peers and
ability to maintain confidentiality.
On the custodian bank’s side: ability to settle trades
with a delivery-against-payment model with the
broker-dealer.
JSSAMNA normally uses the following two broker-dealers:
As disclosed in Item 10 above, we have selected Safra
for securities
Securities, an affiliated broker-dealer
execution services because we believe
that Safra
Securities offers an attractive platform for our business
model while, at the same time, Safra Securities meets the
above-mentioned “best quality execution” criteria.
Directed brokerage
As explained above, we use Safra Securities and Baird for
execution of client transactions. We do not permit clients to
direct or use any other specific broker-dealers for any client
transactions. Not all investment advisers do this. As a
result, we may not be able to achieve the most favorable
execution and this practice may increase your transaction
costs, such as by charge of a brokerage commission for
transactions in certain non-US securities. However, we
believe that in consideration of the “best qualitative
execution” criteria described above, the selected broker-
dealer and settlement process with the custodian bank
provide for the most favorable result for you over time.
We have furthermore selected Robert W. Baird & Co.
Incorporated (“Baird”), a non-affiliated entity that
is
registered as a broker-dealer with the SEC and a member
of the US Financial Industry Regulatory Authority (FINRA) for
securities execution services. Through its international
network and 24-hour trading desk, Baird offers next to
competitive commissions in particular real-time access
during European and Asian market hours. As part of
JSSAMNA’s arrangement with Baird, we also obtain access
to Baird’s proprietary research as an additional channel of
independent research.
Trade aggregation and/or allocation of investment
opportunities
We may aggregate or pool trade orders to buy or sell
financial securities in a way to seek the most favorable
execution and to lower brokerage commissions. All affected
investment advisory portfolios will receive the same
average execution price. We endeavor to allocate executed
trades and/or investment opportunities on a fair and
equitable basis, without favoring any portfolio or client. In
cases when an order is partially completed, we will allocate
both the traded financial instruments and related external
broker’s commissions on a pro rata basis.
We will periodically review the arrangements with Safra
Securities and Baird. In addition, we reserve the right to use
other firms, in addition to or in place of, Safra Securities and
Baird, as we deem warranted.
We cannot guarantee the equal participation of each client
in every investment opportunity or every transaction. In
certain instances such as the limited availability of publicly
traded securities or over-subscribed public offerings, it may
not be possible to allocate a transaction pro rata, especially
10
Firm Brochure | Form ADV Part 2A | March 18, 2026
relationship with us. Any referral fee paid to a solicitor will
not result in any increase of the generally applicable
Advisory Fee or any additional charges to you.
if clients have materially different sized portfolios or if post-
trade allocation becomes substantially different from pre-
trade allocation due to minimum round lots not reached. In
those cases, we randomly allocate executed trades.
Item 15: Custody
Item 13: Review of Accounts
After entering into a business relationship with us, each
client and investment advisory portfolio is assigned to a
Client Relationship Manager.
We do not have direct custody of any client assets. As
specified under Item 10, you may choose BJSS, certain
other affiliates of JSSAMNA, or a non-affiliated custodian
bank as custodian. You should carefully review the
accuracy of any account statement sent by your custodian
bank. We will work with your custodian bank to ensure that
account statements are directly sent to you.
With respect to Discretionary Mandates, our investment
team regularly monitors your discretionary portfolio,
typically on a monthly basis but not less frequently than
quarterly. Each review generally includes consideration of
the following matters:
-
-
-
compliance with agreed investment strategy, i.e.
asset allocation,
investment restriction, product
suitability;
consistency of your investment objectives with your
risk profile; and
any conflicts of interest that may exist.
the
investment objectives
In addition, the appointed Client Relationship Manager
for all assigned
reviews
investment advisory portfolios on an annual basis.
Where BJSS acts as custodian bank of client assets for
which we provide investment advisory services, BJSS is
viewed as a “Qualified Custodian” and subject to certain
requirements as defined in Rule 206(4)-2 of the US
Investment Advisers Act of 1940 (the “Custody Rule”). BJSS
will send quarterly (or more frequent) account statements
directly to clients. Furthermore, and in accordance with the
Custody Rule, JSSAMNA has an internal control report
prepared by an independent public accountant on an
annual basis who in addition also conducts a (surprise)
examination regarding client funds and securities held by
the Qualified Custodian once a calendar year. We have
retained Deloitte SA, Switzerland, as independent public
accountant. Upon request, you may request from us a copy
of the internal control report prepared by Deloitte SA,
Switzerland.
Apart from the regular monthly statement provided by the
custodian bank, we inform you as often as agreed, but no
less frequently than annually, about the performance and
the balance of your investment advisory portfolio.
Item 16: Investment Discretion
Item 14: Client Referrals and Other Compensation
full discretionary authority
We may from time to time refer clients to or receive referrals
from other entities of the JSSH Group, but we do not receive
or pay any remuneration for such referrals.
Occasionally, we may enter into an arrangement with a non-
affiliated solicitor who may refer prospective clients to us
for compensation. Any referral fee is generally calculated
based on a percentage of assets under management of the
referred investment advisory portfolio, or of the fees that we
earn on those assets, and will be disclosed to referred
into a business
prospective clients before entering
Based on a Discretionary Mandate and power of attorney
for the management of assets granted by you on the
discretionary portfolio held at the custodian bank, we will
to manage your
have
discretionary portfolio, including the authority to purchase
or sell any financial instrument in accordance with the
agreed investment strategy. In addition, we may be granted
authority to instruct your custodian bank to debit and pay
our quarterly Advisory Fees.
We allow investment restrictions such as those related to
specific securities, certain types of securities or industries.
Any such restrictions imposed by you on our Discretionary
Mandate may cause the selected investment strategy to
11
Firm Brochure | Form ADV Part 2A | March 18, 2026
differ in performance and risk profile from the unmodified
mandate developed by our investment team, which may be
used by other clients of JSSAMNA.
Item 17: Voting Client Securities (Proxy Voting)
JSSAMNA does not accept proxy voting responsibility for
securities held in your non-discretionary portfolio (i.e.
Advisory Mandate). You must arrange for any corporate
action
information or proxy voting directly with your
custodian bank.
With respect to any discretionary portfolio (i.e. Discretionary
Mandate), and subject to us having received the necessary
information from the custodian bank in time, we will
exercise our investment judgement for corporate actions
such as tender or exchange offers, subscription rights,
option and conversion rights or redemption rights. For all
other votes, such as voting for directors, you remain solely
responsible. Furthermore, we will not advise you on or
make any elections with respect to reorganizations,
bankruptcy proceedings or class action lawsuits involving
an issuer of financial instruments held in your investment
advisory portfolio. You must arrange
for any such
information to be obtained directly from your custodian
bank.
Upon request, you may obtain a copy of our proxy voting
policy and procedures related to your investment advisory
portfolio.
Item 18: Financial Information
We are in sound financial standing and do not have any
condition reasonably likely to impair our ability to meet our
contractual commitments to you.
12
Firm Brochure | Form ADV Part 2A | March 18, 2026
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 49
www.jsafrasarasin.com/northamerica
Additional Brochure: JSSAMNA-WRAP FEE PROGRAM BROCHURE SUPPLEMENT FORM ADV PART 2B (2026-03-25)
View Document Text
Firm Brochure and Wrap Fee Program Brochure
Supplement / Form ADV Part 2B
J. Safra Sarasin Asset Management
(North America) Ltd
March 18, 2026
Supervised Persons:
Thomas H. Maxwell
Tracy Araujo
Nicolas Frick
Felix Fässler
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 10
www.jsafrasarasin.com/northamerica
SEC no.: 801-112502
IARD/CRD no.: 292433
This Form ADV Part 2B disclosure brochure supplement (the “Brochure Supplement”) provides information about the be-
low supervised person(s) employed by J. Safra Sarasin Asset Management (North America) Ltd (“JSSAMNA”, “us” or “we”).
The information contained herein supplements our respective Firm Brochure or Wrap Fee Program Brochure /Form ADV
Part 2A disclosure brochure (the “Brochure”).
You should have received a copy of our Brochure. Please contact us at +41 (0)58 317 64 00 and/or jssamna@jsafrasar-
asin.com if you did not receive it or if you have any questions about the contents of this Brochure Supplement. The infor-
mation in this Brochure Supplement has not been approved or verified by the United States Securities and Exchange
Commission (the “SEC”) or by any state securities authority.
Additional information about JSSAMNA is available on the SEC’s website at www.adviserinfo.sec.gov
Form ADV Part 2B | March 18, 2026
1
Overview of Supervised Persons
Supervised Person: Thomas H. Maxwell
3
Supervised Person: Tracy Araujo
4
Supervised Person: Nicolas Frick
5
Supervised Person: Felix Fässler
6
Form ADV Part 2B | March 18, 2026
2
Supervised Person: Thomas H. Maxwell
Business address: Rue de la Corraterie 4, CH-1204 Geneva,
Switzerland
Direct Phone number: +41 58 317 64 03
Year of birth: 1968
Item 2: Educational Background and Business Experience
Educational background
Bachelor of Law from the University of Geneva and Certified
International Wealth Manager (CIWM) charter holder.
Business experience
Joined JSSAMNA in April 2018 as Chief Executive Officer and
Chief Investment Officer. Prior to that: Executive V.P. Head of
Wealth Management (USA) at Lombard Odier Transatlantic
Ltd, Canada (7 years), and Senior Client Relationship Man-
ager at Bank Lombard Odier and Cie, Switzerland (12 years).
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
Thomas H. Maxwell is the Chief Executive Officer of JSSAMNA
and reports to the Board of Director of JSSAMNA. He oversees
investment advisory services provided to clients and evalu-
ates whether such services are suitable in light of their risk
profile and investment objectives. All JSSAMNA employees
are subject to its policies and procedures, which include
(among others) policies covering the provision of investment
advisory services to clients and compliance with applicable
law. Benedetta Gambatesa, JSSAMNA’s Chief Compliance
Officer, administers its compliance program and can be con-
tacted at the address/telephone number on the cover page.
Form ADV Part 2B | March 18, 2026
3
Supervised Person: Tracy Araujo
Business address: Rue de la Corraterie 4, CH-1204 Geneva,
Switzerland
Direct Phone number: +41 (0)58 317 64 02
Year of birth: 1990
Item 2: Educational Background and Business Experience
Educational background
Bachelor of International Business from the Peruvian Univer-
sity of Applied Sciences and CFA Charter holder.
Business experience
Joined JSSAMNA in April 2018 as Assistant Portfolio Man-
ager. Appointed to Portfolio Manager in April 2023.
Prior to that: Wealth Management Assistant (US market) at
Lombard Odier Transatlantic Ltd, Canada, (3 years).
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
Tracy Araujo is JSSAMNA’s Chief Investment Officer and re-
ports to Thomas Maxwell, JSSAMNA’s Chief Executive Officer.
She is responsible for investing, managing and monitoring
clients’ portfolios according to their risk profile and invest-
ment objectives. Her investment advisory activities are su-
pervised by Thomas Maxwell. All JSSAMNA employees are
subject to its policies and procedures, which include (among
others) policies covering the provision of investment advisory
services to clients and compliance with applicable law. Bene-
detta Gambatesa, JSSAMNA’s Chief Compliance Officer, ad-
ministers its compliance program and can be contacted at
the address/telephone number on the cover page.
Form ADV Part 2B | March 18, 2026
4
Supervised Person: Nicolas Frick
Business address: Rue de la Corraterie 4, CH-1204 Geneva,
Switzerland
Direct Phone number: +41 (0)58 317 64 09
Year of birth: 1987
Item 2: Educational Background and Business Experience
Educational background
Higher degree of education in Banking and Finance from the
HFBF in Zurich.
Business experience
Joined JSSAMNA in June 2021 as Director and Relationship
manager. Appointed to deputy CEO in 2023.
Prior to that: worked in private banking since 2008 and
started to focus on US domiciled clients in 2009. He has also
worked for BSI AG, Zurich (today EFG, 5 years) and Pictet
North America Advisors SA, Zurich (4 years).
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
Nicolas Frick is the deputy Chief Executive Officer of
JSSAMNA and reports to Thomas Maxwell, JSSAMNA’s Chief
Executive Officer. He is responsible for business develop-
ment; relationship management and member of the invest-
ment committee and his investment advisory activities are
supervised by Thomas Maxwell. All JSSAMNA employees are
subject to its policies and procedures, which include (among
others) policies covering the provision of investment advisory
services to clients and compliance with applicable law. Bene-
detta Gambatesa, JSSAMNA’s Chief Compliance Officer, ad-
ministers its compliance program and can be contacted at
the address/telephone number on the cover page.
Form ADV Part 2B | March 18, 2026
5
Supervised Person: Felix Fässler
Business address: Alfred-Escher-Strasse 50, CH-8002 Zurich,
Switzerland
Direct Phone number: +41 58 317 64 01
Year of birth: 1964
Item 2: Educational Background and Business Experience
Educational background
Certified Wealth Management Advisor CWMA) with a Diploma is-
sued by the Swiss Association for Quality (SAQ 2018)
Commercial apprenticeship with Swiss Bank Corporation (now
UBS Switzerland Ltd).
Business experience
Joined JSSAMNA in April 2024 as Relationship Manager and
Team Head PBZH North America.
Prior to that: worked as Relationship Manager and Head Team
Davos at Vontobel Swiss Financial Advisors AG, Zurich (1 year).
He has also worked as Wealth Management Advisor and Head
Wealth Management Advisors in Team Davos Vontobel Swiss
Wealth Advisors AG, Zurich (5 years).
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None.
Item 6: Supervision
Felix Fässler reports to Thomas Maxwell, JSSAMNA’s Chief Exec-
utive Officer. He is responsible for business development; rela-
tionship management and his investment advisory activities are
supervised by Thomas Maxwell. All JSSAMNA employees are
subject to its policies and procedures, which include (among oth-
ers) policies covering the provision of investment advisory ser-
vices to clients and compliance with applicable law. Benedetta
Gambatesa, JSSAMNA’s Chief Compliance Officer, administers
its compliance program and can be contacted at the ad-
dress/telephone number on the cover page.
Form ADV Part 2B | March 18, 2026
6
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 10
www.jsafrasarasin.com/northamerica
Form ADV Part 2B | March 18, 2026
7
Additional Brochure: JSSAMNA-WRAP-FEE-PROGRAM (2026-03-25)
View Document Text
Wrap Fee Program Brochure / Form ADV Part 2A
J. Safra Sarasin Asset Management
(North America) Ltd
March 18, 2026
Wrap Fee Program Brochure / Form ADV Part 2A
change at our discretion. We will provide you annually with
a copy of our updated Wrap Fee Program Brochure or a
summary of material changes from the Wrap Fee Program
Brochure previously provided to you. In addition, you may
also obtain a copy of our current Wrap Fee Program
Brochure at any time free of charge via the above-
mentioned telephone number or e-mail address.
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 10
Item 2: Material Changes
There have been no material changes to the Wrap Fee
Program Brochure since its last annual update and filing on
March 21, 2025.
J. Safra Sarasin Asset Management (North America) Ltd,
Zurich Branch
Alfred Escher Strasse 50
CH-8022 Zurich
Switzerland
Tel. +41 (0)58 317 64 00
www.jsafrasarasin.com/northamerica
SEC no.: 801-112502
IARD/CRD no.: 292433
Item 1: Cover Page
This wrap fee program disclosure brochure (the “Wrap Fee
Program Brochure”) provides
information about the
qualifications and business practices of J. Safra Sarasin
Asset Management (North America) Ltd (“JSSAMNA”, “us”
or “we”). If you have any questions about the contents of
this Wrap Fee Program Brochure, please contact us at +41
(0)58 317 64 00 and/or jssamna@jsafrasarasin.com. The
information in this Wrap Fee Program Brochure has not
been approved or verified by the United States Securities
and Exchange Commission (the “SEC”) or by any state
securities authority.
Additional information about us is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Please note that registration with the SEC as a registered
investment adviser does not imply a certain level of skill or
training.
The information in this Wrap Fee Program Brochure is
current as of the date indicated above and is subject to
Wrap Fee Program Brochure | Form ADV Part 2A | March 18, 2026
1
Item 3: Table of Contents
Item 1: Cover Page
1
Item 2: Material Changes
1
Item 3: Table of Contents
2
Item 4: Services, Fees and Compensation
3
Item 5: Account Requirements and Types of Clients
5
Item 6: Portfolio Manager Selection and Evaluation
5
Item 7: Client Information Provided to Portfolio Managers
8
Item 8: Client Contact with Portfolio Managers
8
Item 9: Additional Information
8
Wrap Fee Program Brochure | Form ADV Part 2A | March 18, 2026
2
Item 4: Services, fees and compensation
investments
Management Agreement (the “Discretionary Mandate”)
with JSSAMNA. Under a Discretionary Mandate, we will
manage your assets on a fully discretionary basis in line
with the agreed investment strategy, taking into account
your investment profile and objectives. We will be solely
responsible for defining the asset allocation, making the
underlying
in your discretionary portfolio
covered by the Discretionary Mandate and periodically
review and adjust the discretionary portfolio in response to
economic, political or market conditions.
About J. Safra Sarasin Asset Management (North America)
Ltd (“JSSAMNA”, “us” or “we”)
JSSAMNA is a corporation organized under the laws of
Switzerland with its head office and main place of business
in Geneva, Switzerland, and a branch
in Zurich,
Switzerland, which was established in September 2024.
We provide
investment advisory services mainly to
individuals, trusts, estates, charitable organizations and
small corporations or similar small business entities
residing in, or organized under the laws of, the United
States of America (the “US”). JSSAMNA may, in certain
limited cases, also advise other clients, such as US citizens
residing outside the US.
We allow investment restrictions such as those related to
specific securities, certain types of securities or industries.
Any such restrictions imposed by you on our Discretionary
Mandate may cause the selected investment strategy to
differ in performance and risk profile from the unmodified
mandate developed by our investment team, which may be
used by other clients of JSSAMNA.
We are a wholly owned subsidiary of J. Safra Sarasin
Holding Ltd, Basel, Switzerland (“JSSH”). JSSH is ultimately
owned and controlled by members of the Joseph Y. Safra
family.
Investment Advisory Agreement
Please refer to the supplement of this Wrap Fee Program
learn more about
Brochure (ADV Form Part 2B) to
JSSAMNA’s key personnel.
Advisory mandate
If you wish to have your assets managed on a non-
into a Non-
discretionary basis, you must enter
(the
Discretionary
“Advisory Mandate”) with JSSAMNA. Under the Advisory
Mandate, we will provide you with our investment views and
recommendations upon request and in accordance with
your investment profile and objectives. We may also
periodically contact you and offer recommendations that
we consider suitable and appropriate for you.
About our investment advisory services
We specialize in tailored investment advisory services to
high net worth clients and offer both discretionary asset
management services as well as non-discretionary
investment advisory services. In doing so, we will make
recommendations based on your investment profile and
objectives.
In contrast to the Discretionary Mandate, you will be solely
responsible for making all investment decisions and we will
not have any discretionary authority over your assets. We
will furthermore not provide continuous and regular
supervision of your non-discretionary portfolio covered by
the Advisory Mandate and will not be responsible for pro-
actively updating any previous investment views and
recommendations in response to economic, political or
market conditions.
Our investment advisory services may cover a variety of
asset classes in US and international markets, including
cash in various currencies, equity and debt securities,
mutual funds, fiduciary deposits, certain derivatives and
(physical) precious metals. Depending on your investment
profile and objectives, we may also consider other types of
investments.
We are not registered as a broker-dealer with the SEC or
any other US or non-US regulatory authority. Accordingly,
we do not provide any brokerage services.
For Advisory Mandates, we generally do not permit any
investment restrictions as any restrictions in your non-
discretionary portfolio would be self-imposed and
controlled by you.
Discretionary mandate
If you wish to have your assets managed on a discretionary
into a Discretionary Asset
basis, you must enter
Assets under management
As of end of December 2025, we provided investment
advisory services for USD 934’502 million in assets under
Wrap Fee Program Brochure | Form ADV Part 2A | March 18, 2026
3
management, of which USD 523’957 million are
in
Discretionary Mandates and USD 407’985 million are in
Advisory Mandates.
charged for our investment advisory services as well as the
above described
included custodian and brokerage
services separately.
Wrap Fee
For our investment advisory services as well as further
services as described in more detail below, we are
compensated on the basis of a wrap fee (the “Wrap Fee”)
calculated at the end of each calendar quarter (31 March,
30 June, 30 September, 31 December) as a percentage of
the entire assets (including cash) held in the client
account(s) of the custodian bank that are covered by either
the Discretionary Mandate or Advisory Mandate.
For our Discretionary Mandate and Advisory Mandate, the
Wrap Fee is an annual rate of 1.60% of your entire assets
(including cash) in the mandate, subject to a minimum
quarterly Wrap Fee of CHF 8,000.
We reserve the right to waive, discount, increase or
otherwise negotiate our Wrap Fees.
Calculation and charging of the Wrap Fee
Although additional custodian banks may be permitted in
the future, Bank J. Safra Sarasin Ltd in Basel, Switzerland
(“BJSS”), must act as custodian bank for Wrap Fee
accounts. The Wrap Fee will be calculated in Swiss francs
based on BJSS’s market valuation of all of the assets
(including cash) held in the client account(s) with BJSS that
are covered by either the Discretionary Mandate or Advisory
Mandate at the end of each calendar month during the
quarter for which the Wrap Fee is charged. The Wrap Fee
will be charged in arrears at the end of the quarter in Swiss
francs to your client account(s) with BJSS. In case the
Discretionary Mandate or Advisory Mandate is terminated,
the Wrap Fee for the entire last calendar month is charged
in full. If your client account(s) with BJSS does not hold
enough Swiss francs, then the debiting of the Wrap Fee will
result in a foreign exchange transaction. BJSS will be
compensated for effecting such a foreign exchange
transaction.
Services included in the Wrap Fee
Our Wrap Fee includes the following services:
-
-
-
-
-
our investment advisory services in regard to your
Discretionary Mandate and/or Advisory Mandate;
the custody, trade settlement and withholding tax
reclaim fees of the custodian bank;
periodic account and portfolio statements provided to
you by the custodian bank;
an annual country-specific US tax report and generic
income statement (incl. realized and unrealized capital
gain and loss) provided to you by the custodian bank;
and
the brokerage commissions on US and certain non-US
securities.
Other expenses
Our Wrap Fee do not include any BJSS fees that are not
foreign currency exchange
listed above such as
transactions, wire transfer or any other fees or taxes (e.g.
value added tax, Swiss stamp tax duty) imposed by BJSS or
other service providers. Our Wrap Fee also does not include
any management or other fees charged by funds or issuers
of other financial instruments you may be invested in.
Depending on the services you request from BJSS or other
service providers, you may additionally be charged for
special services such as safe deposit boxes. All these fees
will reduce the overall return of the investment advisory
portfolio(s) covered by either the Discretionary Mandate or
Advisory Mandate. All these fees as well as the Wrap Fee
will reduce the overall return of the investment advisory
portfolio(s) covered by either the Discretionary Mandate or
Advisory Mandate
For purchases of non-US securities on which a third-party
broker charges a brokerage commission, that commission
will be included in the purchase price, i.e. the commission
will not be paid from the Wrap Fee.
Our Wrap Fee will not be adjusted for (1) low or no trading
activity, or (2) for an Advisory Mandate, if you decide not to
implement or follow the investment advice we provide to
you. As a consequence, our Wrap Fee may, depending on
your investment activity, cost you more than if you are
Management fees to affiliates
If we or you invest in collective investment vehicles and
similar products managed by an affiliate of JSSAMNA, that
affiliate may be economically benefited through the receipt
of a management fee for such products. We will not share
such fees.
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4
No other compensation
We do not accept any compensation for any sale of any
financial instruments, referral of prospective clients or have
any other type of revenue-sharing arrangement with
another party unless disclosed otherwise. In addition, we
do also not charge any transaction-based fees or fees for
transmitting orders to broker-dealers for execution.
Item 5: Account Requirements and Types of Clients
Our policies and procedures aim to ensure that investment
advisory portfolios are treated fairly and equitably over
time. Any investment decisions for such portfolios are
made with specific reference to the individual investment
profile and objective of each client. We may therefore give
investment advice or exercise investment responsibility or
take other actions for clients that may differ from the advice
given, or the timing and nature of actions taken, for other
clients. Investment results for different portfolios, including
portfolios that are generally managed in a similar style, may
also differ as a result of these considerations. Some clients
may not participate at all in some investments in which
other clients participate, or may participate to a different
degree or at a different time.
6.2 Methods of analysis, investment strategies and risk of
loss
As specified under Item 4, we provide investment advisory
services to mainly high net worth individuals, trusts,
estates, charitable organizations and small corporations or
similar business entities who are residing in the US, or
organized under US laws. We may, in certain limited cases,
also advise other clients.
We consider that a minimum Discretionary Mandate or
Advisory Mandate value of USD 3,000,000 allows for most
efficient management and sufficient diversification.
Investment advisory mandates with smaller values may be
accepted based on specific circumstances and we may
aggregate investment advisory mandates that have family,
corporate or other relationships at our discretion.
if
Our investment team defines several investment strategies
that are appropriate to different degrees of risk. All
investments carry a risk of loss. The investment strategy
you select must reflect the risk of loss you are willing to
bear. The higher the expected returns you may have, the
greater the risk you could lose. We consider various factors
to select what we believe to be the most suitable
investment strategy for you. These factors could evolve over
time and may change your risk tolerance, investment
profile and objective as well as the investment strategy
selected by you.
We reserve the right to terminate your participation in a
Discretionary Mandate or Advisory Mandate
the
investment amount falls below the minimum value as
described above. Under normal circumstances, we will not
do so if such decrease in value is attributable to the
performance of your Discretionary Mandate and/or
Advisory Mandate.
- A fixed income or defensive investment strategy may
allow you to seek a modest level of losses and returns,
while accepting low risk and low fluctuation to your
initial principal. These strategies may not generate
significant income and may not keep pace with
inflation.
Item 6: Portfolio Manager Selection and Evaluation
All investment advisory services are provided by our
investment team. No external portfolio manager is in
charge to act as investment adviser for our clients.
-
Performance-based
fees
and
side-by-side
6.1
management
- A dynamic or an equity investment strategy may allow
you to maximize returns over time, but require you to
accept a very high level or risk and fluctuation to your
initial principal. Investors in these strategies may lose
most or all of the initial principal invested.
In between, a balanced investment strategy may
expose your initial principal to moderate risk and
return expectation. However, all or a portion of your
initial principal could still be lost.
We do not charge performance-based fees.
It is of highest importance that we apply sound methods of
analysis and investment strategy to your investment
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-
advisory mandate. Our
investment team periodically
organizes an investment committee, where investment
views are formulated and translated into asset allocation
decisions. We take into consideration economic, political
and market factors, such as gross domestic product,
inflation, short and long-term interest rates. The asset
allocation decisions may impact each risk profile and their
related investment strategies.
-
-
Our investment strategies and advice involve financial
instruments with varying risk degrees, from lower risk (e.g.
cash and high-quality debt securities) to higher risk
investments (e.g. equity securities). Currency allocation,
country exposure and sector weighting are key elements,
which may substantially alter the risk of any strategy. We
generally allocate a higher portion of low risk financial
instruments to conservative strategies, while growth
strategies will be more exposed to riskier financial
instruments.
-
Broadly speaking, we tend to invest in companies with
strong balance sheets, stable earnings and efficient
management. We avoid micro-cap securities, unstable
countries, leveraged investments and businesses that we
do not understand. We do not engage in “day trading”,
“high frequency trading” or any other form of excessive
trading.
-
We regularly monitor your Discretionary Mandate and
usually review its asset allocation, typically on a monthly
basis, but not less frequently than quarterly. We may
engage in more financial instrument transactions on behalf
of clients during any particular quarter depending on
market conditions or changes in client investment strategy.
than
-
factors,
such
as
Generally speaking, all investments are subject to a risk of
financial loss that you should be prepared to bear. You
must understand the factors that can potentially lead to
such loss. Examples of common risk types may include,
without limitation:
- Market risk: prices in any investment can go up and
down
rapidly and unpredictably, caused by
economic
macroeconomic
developments, changes in interest rates, political
changes, and other catastrophic events (e.g. war,
terrorism, climate change, pandemics and public
health issues);
Interest rate risk: debt securities can fluctuate in
value as interest rates change. Central banks may
change interest rates at various times during the
business cycle, which may affect corporate debt’s
income and performance. Also, debt securities with
longer maturity will typically be more sensitive to
changes in interest rates compared to similar ones
with a shorter maturity;
Credit risk: credit risk
is associated with the
uncertainty in an issuer's ability to meet its obligation
to pay interest and/or principal, or even go bankrupt
(sometimes referred to as solvency risk);
Liquidity risk: due to low trading volume, you could be
exposed to the risk of not being able to sell, or buy, a
specific financial instrument. This generally happens
with companies having a small market capitalization
or debt security during period of stress; for instance,
debt securities rated below investment grade, also
called “high yield bonds”, offer better yield, but are
generally more volatile and less liquid than other debt
securities;
Foreign exchange risk or currency risk: this risk
generally arises from the change in value of one
currency against another. Currency exchange rates
can be extremely volatile, especially during times of
political or economic unrest, or as a result of actions
taken by central banks. The risk depends on which
level your
investment advisory portfolio will be
allocated to your reference currency versus another;
Foreign/Emerging markets risk: foreign/emerging
markets are affected by global economic factors and
generally do not have the level of market efficiency
and strict standards in accounting and securities
regulation
in developed countries. Some
foreign/emerging markets may also have less trading
volume, which may make it more difficult to sell a
financial
instrument. You must understand that
investing in foreign/emerging markets come with
much greater risk due to political instability, domestic
problems and currency volatility and may trigger
larger and more frequent price changes in the short
term; and
Concentration risk: we usually describe concentration
risk when the allocation to a market segment or a
company is higher than others. This could be related
to a country, a company, an industry or any specific
financial instruments invested. The concentration risk
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-
-
-
sensitivity, market
perception
of
inflation often have negative effects on the level of
economic activity. There can be no assurance that
inflation will not become a serious problem in the
impact on an
future and have an adverse
investment’s returns.
Risks related to force majeure events: there is a risk
that investments could be impacted by force majeure
events (i.e. events beyond the control of the party
claiming that the event has occurred, such as acts of
God, war, warlike events, civil unrest, instructions and
sanctions by government, terrorism, accidents, labor
strikes, energy blackouts, communication failures,
outbreaks of an infectious disease, pandemic or any
other serious public health concern, or other
unavoidable objective circumstances such as forces
of nature, including bad weather, earthquake, fire,
flood, atmospheric effects, magnetic fields and
similar circumstances). There is a risk that some force
majeure events will adversely affect the ability of a
party (including an investment, a counterparty of such
investment or a counterparty of client) to perform its
obligations until it is able to remedy the force majeure
event. Such a party could also claim force majeure for
nonperformance of
its contractual obligations.
Certain force majeure events (such as an outbreak of
an infectious disease, e.g. COVID-19) could have a
broader negative impact on the world economy and
international business activity generally, or in any of
the countries or jurisdictions in which investments are
located. Additionally, a major
governmental
intervention into industry, including but not limited to
the nationalization of an industry or the assertion of
control over an investment, could result in a loss to a
client. Any of the foregoing would therefore adversely
affect the performance of investments.
6.3 Voting client securities (proxy voting)
-
JSSAMNA does not accept proxy voting responsibility for
securities held in your non-discretionary portfolio (i.e.
Advisory Mandate). You must arrange for any corporate
action information or proxy voting directly with BJSS.
With respect to any discretionary portfolio (i.e. Discretionary
Mandate), and subject to us having received the necessary
information from the custodian bank in time, we will
exercise our investment judgement for corporate actions
may lead to an increased risk (or opportunity) for
additional loss (or profit).
Equity securities risk: equity securities represent an
ownership interest in an issuer rather than a right to
receive a specified future payment. This makes equity
securities more sensitive than fixed income or debt
investments to changes in an issuer’s earnings and
overall financial condition; as a result, equity
securities are generally more volatile than fixed
income or debt investments. Equity securities may
lose value as a result of changes relating to the
issuers of those securities, such as management
performance, financial leverage, or changes in the
actual or anticipated earnings of a company, or as a
result of actual or perceived market conditions that
are not specific to an issuer. Even when the securities
markets are generally performing strongly, there can
be no assurance that equity securities will increase in
value. Because the rights of all of a company’s
creditors are senior to those of holders of equity
securities, shareholders are least likely to receive any
value if an issuer files for bankruptcy.
Debt securities risk: investments in fixed income or
debt securities are subject to the risk of an issuer’s
ability to meet principal and interest payments on the
obligation (credit risk), price volatility due to interest
the
rate
creditworthiness of the
issuer, general market
liquidity (market risk) and potential inability to access
additional financing due, e.g. to high leverage. The
price of a debt instrument generally moves inversely
with interest rates, such that a rise in interest rates
typically causes a fall in value, while a fall in interest
rates typically causes a rise in value. The risk of debt
securities can vary significantly depending upon
factors such as the credit quality of the issuer and the
maturity of the instrument. For example, the issuer of
a security or the counterparty to a contract may could
default or otherwise become unable to honor a
financial obligation, resulting in losses.
Inflation risk: inflation and rapid fluctuations in
inflation rates have had in the past, and could in the
future have, negative effects on the economies and
financial markets, which may in turn affect the
markets in which a strategy or client invests. For
example, wages and prices of inputs increase during
periods of inflation, which can negatively impact
returns on investments. Governmental efforts to curb
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7
and abroad. Neither JSSH nor BJSS are registered with the
SEC as a broker-dealer or investment adviser or with any
other US regulatory authority. As part of the JSSH Group,
JSSAMNA is subject to the consolidated supervision of the
JSSH Group.
such as tender or exchange offers, subscription rights,
option and conversion rights or redemption rights. For all
other votes, such as voting for directors, you remain solely
responsible. Furthermore, we will not advise you on or
make any elections with respect to reorganizations,
bankruptcy proceedings or class action lawsuits involving
an issuer of financial instruments held in your investment
for any such
advisory portfolio. You must arrange
information to be obtained directly from BJSS.
While JSSAMNA and other entities of the JSSH Group do not
share any staff, our Chairman also serves as director
and/or executive manager of BJSS and other entities of the
JSSH Group.
Upon request, you may obtain a copy of our proxy voting
policy and procedures related to your investment advisory
portfolio.
Item 7: Client Information Provided to Portfolio Managers
As specified under Item 6 above, all investment advisory
services are solely provided by our investment team. No
external portfolio manager is in possession of any client
information.
In line with Swiss legal and regulatory requirements,
JSSAMNA is since December 2024 authorized as a portfolio
manager by the Swiss Financial Market Supervisory
Authority FINMA and affiliated with AOOS – Schweizerische
Aktiengesellschaft für Aufsicht (a Swiss company limited by
shares for supervision), a Swiss supervisory organization
(SO) and self-regulatory organization (SRO) duly recognized
and approved by FINMA. Whilst the SO supervises
JSSAMNA’s conduct as a portfolio manager, the SRO
assumes a supervisory role in the context of combating
money laundering and the financing of terrorism as per
applicable Swiss law.
Item 8: Client Contact with Portfolio Managers
There are no restrictions to contact your Client Relationship
in regard to our
investment team
Manager or our
investment advisory services or your investment advisory
portfolio. Our business hours are from 9.00am to 6.00pm
(Central European Time).
Item 9: Additional Information
JSSAMNA is furthermore affiliated with the Swiss Banking
Ombudsman. In case of a dispute with JSSAMNA, you may
approach the Swiss Banking Ombudsman, Bahnhofplatz 9,
P.O. Box, 8021 Zurich (www.bankingombudsman.ch). The
Ombudsman deals with specific complaints which are
raised against banks and other financial services providers
such as portfolio managers based in Switzerland. He is
independent and neutral and he treats inquiries strictly
confidential. The mediation process is free of charge.
9.1 Disciplinary information
As of the date of this Wrap Fee Program Brochure, there is
no disciplinary information to report.
9.2 Other financial industry activities and affiliations
General comment
As described under Item 4, JSSAMNA is a wholly owned
subsidiary of JSSH. JSSH also owns BJSS, a Swiss bank
licensed and supervised by the Swiss Financial Market
Supervisory Authority FINMA with its principal office in
Basel, Switzerland. BJSS provides banking and investment
services for private and institutional clients in Switzerland
Material relationships with affiliated entities
There are various
forms of arrangements between
JSSAMNA and its affiliates as described further below,
some of which inherently involve material conflicts of
interest. Before participating in JSSAMNA’s wrap fee
program, you should understand these arrangements and
the conflicts they pose. While we generally believe that
BJSS and other affiliates identified below provide services
of comparable quality and, to the extent applicable, at
comparable prices to other market participants, we do not
independently evaluate, and we do not represent, whether
that is or remains the case. Furthermore, JSSAMNA
requires its affiliates to limit the use of any information to
the purpose for which it was provided and to keep them
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-
confidential
laws and
in accordance with applicable
regulations. More details are available in our Data Privacy
Statement.
-
rates between and among
-
-
for effecting
-
-
In case
-
-
Custody and banking services: while other custodian
banks may be permitted in the future, you currently
may select only BJSS as custodian bank for assets
investment advisory services.
covered by our
Depending on your country of residence, you may
obtain limited complementary banking services from
BJSS as permitted under the local requirements in
your home jurisdiction. The fees for BJSS’s services
may be more or less favorable than those that may be
obtained from other custodian banks. We are not
party to any BJSS’s services and do not receive
compensation in relation to these arrangements.
While our Wrap Fees will be deducted directly from
your account(s) with BJSS, we do not have custody of
your assets. You will furthermore receive periodic
account statements for your investment advisory
portfolio directly from BJSS. In addition, as custodian
bank, BJSS charges
foreign
fees
exchange transactions or other services not covered
by the Wrap Fee.
Execution services: for your investment advisory
portfolio, JSSAMNA will, consistent with our duty of
best execution, route securities orders to either Safra
Securities LLC (“Safra Securities”), an affiliate that is
registered as a broker-dealer with the SEC and a
member of the US Financial Industry Regulatory
Authority (FINRA) or other broker-dealers as disclosed
further
in section 9.4 below. Fees charged to
JSSAMNA by Safra Securities will be absorbed by our
Wrap Fee except for brokerage commissions that may
be charged for certain non-US securities by third party
brokers used by Safra Securities that will be charged
to you directly as part of the purchase price of the
security. The fees for Safra Securities’ services may
be more or less favorable than those that may be
obtained from non-affiliated third-parties. We do not
receive compensation in relation to this arrangement.
While Safra Securities does not receive additional
compensation from you when we select them to
execute transactions on your behalf, we have an
incentive to place trades through Safra Securities,
rather than a third party, such as Baird (see Item 9.4
below for more information).
in
investments
Cash/Currency accounts: cash
various currencies
investment advisory
in your
portfolio are held with BJSS as custodian bank and
you are therefore exposed to the credit risk of BJSS.
Moreover, if you hold cash or assets denominated in
multiple currencies, you will be exposed to fluctuating
exchange
those
currencies.
Fiduciary deposits: unless instructed otherwise by
you, fiduciary deposit investments in your investment
advisory portfolio will be placed via BJSS in their own
name, but at your risk with BJSS’s recommended
fiduciary counterparties at the point of time of the
investment. The fiduciary counterparties are generally
affiliates of BJSS and such placements are therefore
exposed to the credit risk of such affiliates as well as
BJSS itself. We, and BJSS, have a financial incentive
to make such fiduciary deposit investments with
affiliates of BJSS.
Derivatives: over-the-counter derivative investments
in your investment advisory portfolio such as foreign
exchange forwards will be placed with BJSS and you
are therefore exposed to the credit risk of BJSS. BJSS
charges fees in connection with such transactions,
and accordingly we have a conflict of interest in
selecting BJSS.
Precious metals: precious metal investments in your
investment advisory portfolio are held with BJSS as
custodian bank.
that precious metal
investments are not held in physical form, you are
exposed to the credit risk of BJSS.
Research and joint investment meetings: in addition
to research obtained by non-affiliated entities,
JSSAMNA may obtain research reports prepared by
BJSS and participate in periodic investment meetings
in order to share macroeconomic views, asset
allocation and investment ideas. We are not required
to follow or agree with these views and ideas of BJSS,
and our investment team has the discretion to take
positions for your investment advisory portfolio that
deviate from the ones taken by BJSS.
Shared premises: JSSAMNA and BJSS are located in
the same building and we share office space and
common areas. However, our own workspace and
documents storage room stay physically segregated
from those of BJSS and any information related to
current, former and prospective clients are kept
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information barriers and other restrictions (including
separate trading systems and staff) are in place between
JSSAMNA and such affiliates/related persons, such that
neither party is aware of, nor has access to, the investment
advisory recommendations or trades of the other affiliated
entity made on behalf of its respective clients.
confidential. Appropriate access controls are
enforced to comply with this rule.
Corporate support services: BJSS provides various
support services that are generally unrelated to our
investment advisory services to you such as facility
management, IT and telephone infrastructure, human
resources, mailing services, controlling or
legal
support.
9.4 Brokerage practices
9.3 Code of Ethics, participation or interest in client
transactions and personal trading
Broker-dealer selection
We have an obligation to seek “best execution” for client
transactions. Best execution generally refers to the
execution of transactions in such a manner that the total
costs or proceeds in each transaction are the most
favorable under the circumstances. The SEC defines best
execution as “best qualitative execution” and not merely
the lowest possible execution cost. When evaluating the
quality of execution provided by our selected broker-
dealers, we will review the following factors:
-
Code of Ethics
We have adopted a Code of Ethics which sets forth
standards of business conduct that apply to all our
employees, reflect our fiduciary obligations to act in your
best interest, and addresses prevention of any conflict of
interest associated with the personal trading activities of
our employees and certain members of their families. All of
them must periodically submit specific reports which reflect
their current personal securities holdings, as well as their
most recent securities transactions. Our Chief Compliance
Officer reviews these reports on a regular basis and
ensures our employees or certain members of their families
do not take inappropriate advantage of their positions in
relation to your investment advisory portfolio.
-
On the broker-dealer’s side: financial strength,
markets coverage, settlement efficiency, quality of
communication, level of commission vs. peers and
ability to maintain confidentiality.
On the custodian bank’s side: ability to settle trades
with a delivery-against-payment model with the
broker-dealer.
JSSAMNA normally uses the following two broker-dealers:
We also have policies and procedures that are designed to
prevent the misuse of material and non-public information
which may become available to us via you or other means.
Our employees are prohibited from using such information
for you, their benefit or the benefit of third parties.
As disclosed in section 9.2 above, we have selected Safra
Securities, an affiliated broker-dealer
for securities
that Safra
execution services because we believe
Securities offers an attractive platform for our business
model while, at the same time, Safra Securities meets the
above-mentioned “best quality execution” criteria.
Any employee who fails to respect the provisions of the
Code of Ethics can be subject to sanctions, which may
include verbal warnings, suspension of personal trading
rights, disgorgement of profits and, in most severe cases,
the possibility of dismissal or to be reported to the relevant
authorities.
We can provide you with a copy of our Code of Ethics upon
request.
Affiliate/Related person transactions
As described under Item 4, JSSAMNA is a wholly owned
subsidiary of JSSH and thus part of the JSSH Group. Certain
affiliates and related persons of JSSAMNA such as BJSS
may from time to time invests in securities that are also
its clients. However,
recommended by JSSAMNA to
We have furthermore selected Robert W. Baird & Co.
Incorporated (“Baird”), a non-affiliated entity that
is
registered as a broker-dealer with the SEC and a member
of the US Financial Industry Regulatory Authority (FINRA) for
securities execution services. Through its international
network and 24-hour trading desk, Baird offers next to
competitive commissions in particular real-time access
during European and Asian market hours. As part of
JSSAMNA’s arrangement with Baird, we also obtain access
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to Baird’s proprietary research as an additional channel of
independent research.
cases when an order is partially completed, we will allocate
the traded financial instruments on a pro rata basis.
We will periodically review the arrangements with Safra
Securities and Baird. In addition, we reserve the right to use
other firms, in addition to or in place of, Safra Securities and
Baird, as we deem warranted.
We cannot guarantee the equal participation of each client
in every investment opportunity or every transaction. In
certain instances, such as the limited availability of publicly
traded securities or over-subscribed public offerings, it may
not be possible to allocate a transaction pro rata, especially
if clients have materially different sized portfolios or if post-
trade allocation becomes substantially different from pre-
trade allocation due to minimum round lots not reached. In
those cases, we randomly allocate executed trades.
Research and other soft dollar benefits
We did not select Safra Securities and Baird, and will
generally not in the future select any other broker-dealer,
for securities transactions based upon a soft commission
or soft dollar arrangement.
9.5 Review of accounts
After entering into a business relationship with us, each
client and investment advisory portfolio is assigned to a
Client Relationship Manager.
We receive third party research via Safra Securities as well
as proprietary research prepared by Baird and BJSS,
including periodically and publically available newsletters
as well as access to their research platform. These
materials are provided to us free of charge, i.e. do not result
in a different level of commissions or fees charged, and not
subject any transaction volume directed to a particular
broker-dealer. We do not consider the provision of research
or other services when evaluating execution services.
With respect to Discretionary Mandates, our investment
team regularly monitors your discretionary portfolio,
typically on a monthly basis but not less frequently than
quarterly. Each review generally includes consideration of
the following matters:
-
-
-
compliance with agreed investment strategy, i.e.
investment restriction, product
asset allocation,
suitability;
consistency of your investment objectives with your
risk profile; and
any conflicts of interest that may exist.
the
investment objectives
In addition, the appointed Client Relationship Manager
reviews
for all assigned
investment advisory portfolios on an annual basis.
Directed brokerage
As explained above, we use Safra Securities and Baird for
execution of client transactions. We do not permit clients to
direct or use any other specific broker-dealers for any client
transactions. Not all investment advisers do this. As a
result, we may not be able to achieve the most favorable
execution and this practice may increase your transaction
costs, such as by charge of a brokerage commission for
transactions in certain non-US securities. However, we
believe that in consideration of the “best qualitative
execution” criteria described above, the selected broker-
dealer and settlement process with the custodian bank
provide for the most favorable result for you over time.
Apart from the regular monthly statement provided by the
custodian bank, we inform you as often as agreed, but no
less frequently than annually, about the performance and
the balance of your investment advisory portfolio.
9.6 Client referrals and other compensation
We may from time to time refer clients to or receive referrals
from other entities of the JSSH Group, but we do not receive
or pay any remuneration for such referrals.
Trade aggregation and/or allocation of investment
opportunities
We may aggregate or pool trade orders to buy or sell
financial securities in a way to seek the most favorable
execution and to lower brokerage commissions. All affected
investment advisory portfolios will receive the same
average execution price. We endeavor to allocate executed
trades and/or investment opportunities on a fair and
equitable basis, without favoring any portfolio or client. In
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We allow investment restrictions such as those related to
specific securities, certain types of securities or industries.
Any such restrictions imposed by you on our Discretionary
Mandate may cause the selected investment strategy to
differ in performance and risk profile from the unmodified
mandate developed by our investment team, which may be
used by other clients of JSSAMNA.
9.9 Financial information
Occasionally, we may enter into an arrangement with a non-
affiliated solicitor who may refer prospective clients to us
for compensation. Any referral fee is generally calculated
based on a percentage of assets under management of the
referred investment advisory portfolio, or of the fees that we
earn on those assets, and will be disclosed to referred
prospective clients before entering
into a business
relationship with us. Any referral fee paid to a solicitor will
not result in any increase of the generally applicable Wrap
Fee or any additional charges to you.
9.7 Custody
We are in sound financial standing and do not have any
condition reasonably likely to impair our ability to meet our
contractual commitments to you.
We do not have direct custody of any client assets. As
specified in section 9.2 above, you currently must choose
BJSS as custodian bank. You should carefully review the
accuracy of any account statement sent by BJSS. We will
work with BJSS to ensure that account statements are
directly sent to you.
BJSS is viewed as a “Qualified Custodian” and subject to
certain requirements as defined in Rule 206(4)-2 of the US
Investment Advisers Act of 1940 (the “Custody Rule”). BJSS
will send quarterly (or more frequent) account statements
directly to clients. Furthermore, and in accordance with the
Custody Rule, JSSAMNA has an internal control report
prepared by an independent public accountant on an
annual basis who in addition also conducts a (surprise)
examination regarding client funds and securities held by
the Qualified Custodian once a calendar year. We have
retained Deloitte SA, Switzerland, as independent public
accountant. Upon request, you may request from us a copy
of the internal control report prepared by Deloitte SA,
Switzerland.
9.8 Investment discretion
instrument
Based on a Discretionary Mandate and power of attorney
for the management of assets granted by you on the
discretionary portfolio held at BJSS, we will have full
discretionary authority to manage your discretionary
portfolio, including the authority to purchase or sell any
in accordance with the agreed
financial
investment strategy. In addition, we may be granted
authority to instruct BJSS to debit and pay our quarterly
Wrap Fees.
Wrap Fee Program Brochure | Form ADV Part 2A | March 18, 2026
12
J. Safra Sarasin Asset Management (North America) Ltd
Rue de la Corraterie 4
CH-1204 Geneva
Switzerland
Tel. +41 (0)58 317 64 00
Fax +41 (0)58 317 64 49
www.jsafrasarasin.com/northamerica